The Renewable Energy Law Review: Vietnam
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:
- initiate a renewable energy market;
- introduce reasonable feed-in tariffs (FITs) and investment protection policy;
- set out applicable renewable energy standards;
- regulate the net-metering mechanism;
- grant incentives for development and use of renewable energy (e.g., import duty, corporate income tax and land use rights); and
- 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 2020 is witnessing numerous regulations being 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.
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 the PDP 8, the first draft of which is expected to be released in June 2020. Predictably, renewable energy will constitute a greater proportion of the total installed capacity.
The number of renewable energy projects increased significantly in 2019, especially solar and wind power projects. According to data from Vietnam Electricity (EVN), by the end of 2019, 5,039MW of solar and wind power was generated for the national grid, achieving rankings of second and 23rd place for renewables generation in the ASEAN region and the world respectively. In addition, thousands of megawatts of electricity are expected to be generated from solar and wind sources in 2020.3 However, the market development of biomass and solid-waste power projects has been poor in comparison with that of solar power projects.
Furthermore, 2019 was also a difficult time for developers of commercially operated solar and wind power projects. To clarify, solar and wind power development has been concentrated in specific areas in Southern Vietnam, such as Binh Thuan and Ninh Thuan provinces, where the power load demand used to be low, but rising demand has meant that the solar and wind farms in these areas are likely to curtail the local power grid if operating at full capacity. This has caused the National Load Dispatch Center to impose restrictions on the production output of wind and solar farms in these areas.4 The MOIT has proposed numerous solutions to the government to deal with the curtailment, including allowing private companies to invest in building the national transmission grid.5
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.6
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. However, the entry into effect of the new Law on Planning7 may have implications for projects whose planning is currently pending, as procedures completed pursuant to the previous legislation may be overriden and invalidated by the transitionary provisions of the new Law. In particular, under the new Law, all project proposals, regardless of their capacity, must be submitted to the MOIT for appraisal. The Prime Minister will then decide whether to approve the project for inclusion in the power development plans. This material change of policy means that approval for projects may be suspended until a resolution is passed by the National Assembly on the implementation of the Law on Planning to clarify the application of the Law's transitionary provisions to pending projects.
Notably, pursuant to the recent Decision No. 13 on the promotion of solar power projects (see below), EVN is no longer to be the sole offtaker for all renewable energy projects.
ii The regulatory framework
There are the following specific pieces of Vietnamese legislation on renewable energy:
- 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;
- Decision No. 24/2014/QD-TTg (issued on 24 March 2014, and effective as of 10 May 2014), Decision No. 08/2020/QD-TTg (issued on 5 March 2020, and effective as of 25 April 2020) (Decision No. 8), Circular No. 44/2015/TT-BCT (issued on 9 December 2015, and effective as of 25 January 2016) (Circular No. 44), and Circular No. 54/2018/TT-BCT (issued on 25 December 2018, and effective as of 18 February 2019) on biomass power (Circular No. 54);
- Decision No. 31/2014/QD-TTg (issued on 5 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
- Decision No. 13/2020/QD-TTg (issued on 6 April 2020, and effective as of 22 May 2020) (Decision No. 13) on solar power (a new circular from the MOIT providing guidance on the implementation of Decision No. 13 is expected soon).
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.
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.
Overall, renewable-energy projects in Vietnam have been granted incentives as follows:
- exemption from import duties applicable to the imported materials, equipment and facilities forming the fixed assets of the renewable-energy project;
- 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;
- 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;
- capital mobilisation will be made in accordance with prevailing laws and regulations; and
- 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
Although EVN remains the sole offtaker for wind, biomass and solid-waste power projects, the recent Decision No. 13 offers a more market-friendly approach for solar power projects, with electricity purchasers now also including electricity retail and distribution units that do not operate under the aegis of EVN. Accordingly, EVN is no longer a single market participant with an electricity market monopoly as formerly established under Decision No. 11/2017/QD-TTg on the development of solar power projects (Decision No. 11). This is a positive change in line with the development orientation of Vietnam's electricity market, in a transition planned to develop from a wholesale electricity market in 2019 into a retail electricity market by 2025.8
Power purchase agreements
At present, 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 (or direct PPAs (DPPAs)) are technically not possible at present. However, on 21 January 2020, the MOIT submitted Proposal No. 544/TTr-BCT to the Prime Minister regarding the approval of a pilot programme for a DPPA mechanism between renewable energy developers and private power purchasers. Under this Proposal, the MOIT would apply the pilot programme on a nationwide scale with a limited capacity of between 400MW and1,000MW. At the time of writing, the Prime Minister has yet to approve the Proposal.
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.
Solar development in Vietnam has been blooming since the introduction of an attractive solar FIT under Decision No. 11. However, Decision No. 11 expired on 30 June 2019 without any immediate replacement and the former FIT applicable under Decision No. 11 is no longer applicable to solar projects with a commercial operation date (COD) after 30 June 2019, thus many solar developers have had misgivings and proved hesitant about pursuing further solar development projects in Vietnam. However, perhaps better late than never, after extensive consideration of multiple draft versions, the long-awaited new support mechanism for solar power projects in Vietnam, Decision No. 13, was officially issued by the Prime Minister on 6 April 2020.
As at the end of 2019, Vietnam had 85 solar power plants with total capacity of 4,459MW in commercial operation and a further 126 projects with total capacity of 8,960MW included in power development plans.9 The issuance of Decision No. 13 is expected to further promote the interests of developers investing in solar power projects in Vietnam.
The following are highlights from the specific regulations on solar power projects.
Types of solar PV projects
Similarly to Decision No. 11, Decision No. 13 regulates solar power projects that generate electric power through the conventional solar PV power system; accordingly, there are two types of solar power projects: roof-mounted (or rooftop) and grid-connected. The difference between Decision No. 11 and Decision No. 13 is that the latter details specifically the project forms in each type of solar power project.
Rooftop solar power projects are systems with solar panels installed on the rooftops of constructed buildings and a maximum installed capacity of 1MWp, connecting directly or indirectly to the purchaser's power grid at a voltage of 35kV or below. Specifically, Decision No. 13 classifies rooftop solar power projects into two subtypes: (1) projects selling their electricity production partly or wholly to EVN, and (2) projects selling their electricity production partly or wholly to other purchasers in the event of not being directly connected to the EVN grid.
Grid-connected solar projects are those that connect directly to the national grid but are not rooftop projects. Decision 13 clearly stipulates two models of grid-connected projects: floating solar projects (i.e., projects with solar panels installed on a water surface) and ground-mounted solar projects (i.e., grid-connected projects other than floating solar projects).
Decision No. 13 now introduces a general FIT applicable to projects located in all provinces of Vietnam except Ninh Thuan, and a separate (higher) FIT for projects located in Ninh Thuan province.
For projects not located in Ninh Thuan, Decision No. 13 differentiates fixed FIT rates according to project type (and not by radiation region), as follows:
|Floating solar projects||1,783 Dong/kWh||7.69 US cent/kWh|
|Ground-mounted projects||1,644 Dong/kWh||7.09 US cent/kWh|
|Roof-mounted projects||1,943 Dong/kWh||8.38 US cent/kWh|
The above FITs will apply for 20 years from the commercial operation date (COD) of projects that fulfil the following conditions:
- Grid-connected solar power projects must have an investment policy approved before 23 November 2019, with COD achieved in the period from 1 July 2019 to 31 December 2020 and have solar cell efficiency greater than 16 per cent or solar module efficiency greater than 15 per cent. (For projects not fulfilling these conditions, the purchase price of electricity shall be determined by a 'competitive mechanism', which is understood to be a price auction mechanism under Decision No. 13, soon to be trialled by the MOIT and EVN).
- Rooftop solar power projects must be connected directly to the EVN grid and sell the electricity to EVN, with a COD and certifying meter readings in the period from 1 July 2019 to 31 December 2020. (For projects not directly connected to the EVN grid and selling electricity to individuals or entities other than EVN, the purchase price is to be agreed between the parties.)
The applicable FIT for solar power projects in Ninh Thuan that have been included in the national or provincial power development plans and reach COD before 1 January 2021 will be 2,086 Dong/kWh (equivalent to 9.35 US cents/kWh). This special exception complies with Government Resolution No. 115/NQ-CP dated 31 August 2018 on special mechanisms and policies applicable to Ninh Thuan in the period between 2018 and 2023. The FIT for projects in Ninh Thuan province that are unable to meet the COD deadline by 1 January 2021 will be determined by a competitive mechanism, which will be introduced at that time.
A circular from the MOIT providing guidance on the implementation of Decision No. 13 is expected soon. Accordingly, it is anticipated that other requirements applicable to solar power projects in Vietnam may also be announced.
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.
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 partially or wholly 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. The MOIT has currently proposed to the Prime Minister that the FIT regime under Decision No. 39 be extended to 31 December 2023.13 At the time of writing, this MOIT proposal has not been approved by the Prime Minister.
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).
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). Decision No. 24 has subsequently been amended by Decision No. 8. The legal documents providing guidance on the implementation of these decisions are Circulars Nos. 44 and 54 (see Section III.ii).
Types of biomass power projects
Pursuant to Decision No. 8, grid-connected projects are the only type of biomass project subject to regulation. This represents a significant departure from Decision No. 24, which covered both grid-connected and non-grid-connected projects. A grid-connected biomass project can supply power partially or wholly to the national grid.
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.
Decision No. 8 sets out the electricity selling price for grid-connected biomass power projects as follows:
- for combined heat and power projects: 1,634 dong/kWh (7.03 US cents/kWh excluding VAT); and
- for other biomass power projects, according to the avoided cost tariff for projects other than combined heat and power projects: 1,968 dong/kWh (8.47 US cents/kWh excluding VAT).
Electricity selling prices are adjusted according to fluctuations of the dong/US$ exchange rate.
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.14 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.15 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.
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.
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.16 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).
The year 2019 witnessed a boom in the number of roof-mounted solar power projects. By the end of 2019, there were a total of 19,379 rooftop projects in Vietnam (with 73 per cent of these in Southern Vietnam) with total installed capacity of 318MW.17 The number of roof-mounted projects is expected to increase further with the entry into effect of Decision No. 13.
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.
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.18
The government is finding ways to deal with these challenges and Decision No. 13 can be seen as an effort by the government to solve the problems that solar projects are facing. It is also 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), but above all, in breaking EVN's monopoly as the single purchaser of electricity, Decision No. 13 has undeniably opened a new chapter for the development of solar power projects in Vietnam.
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:
- 2018–2020: amending the FIT system;
- 2018–2023: preparing for auctions implementation; and
- 2020–2023: parallel use of FITs and auctions for existing projects.
While the government has increased the FIT for biomass projects, solutions for solid-waste 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.
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 Forbes Vietnam, VCEA: Lĩnh vực năng lượng tái tạo sẽ phát triển sôi động thời gian tới (9 February 2020), https://forbesvietnam.com.vn/tin-cap-nhat/vcea-linh-vuc-nang-luong-tai-tao-se-phat-trien-soi-dong-thoi-gian-toi-9203.html accessed on 7 May 2020 (Vietnamese).
4 Ngoc Hien, Điện gió, điện mặt trời phải giảm công suất để không quá tải (2 July 2019), Tuoi Tre News https://tuoitre.vn/dien-gio-dien-mat-troi-phai-giam-cong-suat-de-khong-qua-tai-20190702091531642.htm accessed on 7 May 2020 (Vietnamese).
5 Ha Mai and Nguyen Nga, Tư nhân sẽ được tham gia truyền tải điện? (4 May 2020), Thanh Nien Newspaper, https://thanhnien.vn/tai-chinh-kinh-doanh/tu-nhan-se-duoc-tham-gia-truyen-tai-dien-1219073.html accessed on 07 May 2020 (Vietnamese).
6 Vietnam Energy Online, Không được lợi dụng dự án điện gió để khai thác titan (27 April 2018),
gio-de-khai-thac-titan.html accessed on 17 April 2019 (Vietnamese).
7 The Law on Planning No. 21/2017/QH14 dated 24 November 2017, effective from 01 January 2019.
8 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.
9 Forbes Vietnam; see footnote 3.
10 Vietnam Energy Online, 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.
12 Decision No. 4715/QD-BCT dated 16 August 2012, http://binhthuantpc.vn/bai-viet/bo-cong-thuong-
13 MOIT Proposal No. 2419/BCT-DL dated 9 April 2020 submitted to the Prime Minister.
14 Phuong Nhung, Điện rác kén nhà đầu tư (5 January 2019), Labour newspaper (Vietnamese).
15 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).
16 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.
17 Ministry of Industry and Trade report dated 6 December 2019, attached to the draft decision on developing solar power projects in Vietnam.
18 Phuong Nhung, Điện rác kén nhà đầu tư (5 January 2019), Labour newspaper (Vietnamese).