These comments are submitted on behalf of the Consumers Council of Canada ( CCC ).
The proposed regulation reflects the work of the IESO in consultation with the OPA, AMPCO, and
AAPrO. Groups, like the CCC and the Public Interest Advocacy Center, representing the interests of
residential ratepayers, were not consulted. As a result, the effect of the proposed regulation
benefits large consumers at the expense of residential ratepayers.
There is no data accompanying the description of the proposed regulation. It is evident that costs
will be shifted from large to small consumers. However, It is impossible to tell the scale of the
shift in costs, and, therefore, the impact on residential ratepayers. Among other things, this
makes meaningful commentary on the proposed regulation effectively impossible.
The burden of paying the Global Adjustment will fall disproportionately on residential ratepayers,
the category of consumers with the least flexibility to shift load, change energy sources, and
reduce demaind. The proposal is, thus, at odds with the government's stated desire to reduce the
burden of energy costs on residential ratepayers. It also comes at a time when residential
consumers are seeing their electricity costs rise dramatically.
To the extent that the proposed regulation reflects an attempt to promote or preserve industrial
activity, that should be done from general revenues and not through the allocation of the burden of
the Global Adjustment.
The Global Adjustment includes many types of costs, for example the costs of programs for
conservation, that are unrelated to reduction in peak demand. It is not apparent that these other
types of costs have been included in the development of the proposed regulation.
The proposed regulation should not come into effect until there has been meaningful consultation
with groups representing residential ratepayers. As part of that consultation, the IESO and the
Ministry should disclose the scale of the shift in costs to residential consumers, so that the
burden on those ratepayers can be understood. Finally, the invitation to comment should include
full and accurate disclosure of the impact of the proposed regulation on residential consumers.