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Federation Submission on Energy Consumer Protection Act


The Energy Consumer Protection Act

Bill 235

Submission to the Standing Committee on General Government

Federation of Metro Tenants' Associations


The Federation of Metro Tenants' Associations (FMTA) has an acute interest in so-called smart meters because for the last two years we have been helping thousands of tenants deal with unfair and apparently unlawful schemes of landlords and smart meter sales people.

We appreciate Bill 235 will provide protection for tenants in the future, although we await the all important regulations.  We also appreciate that we have been invited to participate in the consultative process.

We also believe that Bill 235 is an improvement over the unproclaimed sections of the Residential Tenancies Act dealing with smart sub metering.

But this Bill and smart meters are not an energy conservation strategy.  Smart meters could be a helpful instrument in encouraging some energy conservation.  Public education and goodwill will be a better tool.  As was pointed out by Karen Andrews of the Advocacy Centre for Tenants Ontario, people re-cycle and use blue boxes because it is the right thing to do.

All citizens can conserve better, but the myth from landlords and smart meter companies that there can be massive reductions by tenants is disingenuous.

Tenants are not big energy users.  Our homes are smaller.  Many tenants spend little time at home. Those who do include families with children, seniors, people with health problems, and some who make part of their living (to pay the rent) by working at home. The growth of smart meters will affect all of those tenants when seeking accommodation and not given a choice of utilities included.   The ill advised continuation of vacancy de-control under the Residential Tenancies Act will be made worse.

As has been pointed out, landlords have more control and more ability to reduce energy through positive capital expenditures and maintenance.  Passing on their mistakes to tenants is not a good idea.

We would be more inclined to like smart meters if they were being installed by publicly owned utility companies, and that tenants and landlords worked together to reduce energy consumption with half the savings going to the tenants. 

Many tenants are concerned about the devices themselves and that they may be a health hazard.  We hope that can be addressed in regulations.

And then there is the harmonized sales tax.  As of July 1, utility costs will increase by 8%.  We have asked the Government to not charge the HST on hydro or heat, but have not received any answer.

So, we conclude by saying that Bill 235 should be passed with the amendments put forward by the Advocacy Centre for Tenants Ontario.

But then let us get on with bringing forward a better win-win-win strategy that will benefit tenants, landlords, and the environment.

The FMTA has worked for the better interests of tenants since 1974. We are a non profit incorporated organization with a volunteer Board of Directors.  We participated fully in the hearing held by the Ontario Energy Board in 2009, leading to their Order and Decision of August 13, 2009.

March 23, 2010

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