Revised Ontario Proposal Would Preserve Enbridge Open Bill Access

July 7, 2011
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The Ontario Energy Board has revised a proposal regarding natural gas distributors' customer service policies to adopt a less prescriptive approach, and now only proposes to direct each distribution company to develop a "Customer Service Policy" for its residential customers (EB-2010-0280).

The revised proposal requires the development of a customer service policy at each distribution company related to seven areas, but does not make prescriptive regulations for such policies. Notably, this would apparently permit Enbridge Gas Distribution and Union Gas to continue their current policies allocating partial payments to the oldest charges first, regardless of their type (regulated or competitive), while also permitting the continued operation of Enbridge's open bill access and purchase of receivables program without modification.

Originally, the Board had proposed grafting current electricity distributor regulations onto the gas distributor code. Among other things, this proposal held that,
"[c]ustomers should not be exposed to late payment charges or disconnection by reason of partial payments being allocated in whole or in part to non-gas charges," which could have interfered with current practice at Enbridge and Union Gas.

Under the revised proposal, gas distributors must only develop a policy for the allocation of payments between gas and non-gas charges, which explains, at a minimum, how a customer's payments are apportioned between the different line items on a bill.

The Customer Service Policy shall also address the following in addition to allocation of partial payments:

- Bill issuance and payment;

- Correction of billing errors;

- Equal payment and equal billing plans;

- Disconnection for non-payment;

- Security deposits;

- Arrears management programs; and

- Management of customer accounts

In response to the Board's initial proposal, Enbridge requested to maintain its current policies and practices (such as open bill access and POR), and thus will likely do so given the flexibility in the new proposal.

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