NOTL Hydro engages in advocacy efforts in which we position ourselves as representing our ratepayers and petition the government on both their policies and their operational decisions. NOTL Hydro does this because:
- There are many stakeholders trying to influence government policy to further their own interests. However, we do not feel that the interests of the customers are always being heard.
- There is an asymmetry of knowledge as most electricity industry participants are deeply versed in electricity policies and regulations while customers generally are not.
- The NOTL Hydro Board and Management have the knowledge and resources to speak on the specifics of government electrical policy. Despite our knowledgeable customers, it is unrealistic to expect customers to spend the time and energy to obtain this knowledge.
- NOTL Hydro is effectively owned by our customers via our ownership by the Town. We believe this gives us license to try to speak on behalf of our customers.
There are clear guidelines we try to follow in our advocacy efforts. These include:
- We are non-partisan. It may not have always appear this way as much of our advocacy was directed against the Green Energy Act but that was about what was in the Green Energy Act and not whose policy it was.
- We stick to the provincially run electricity industry in which we are a participant and about which we are knowledgeable. We have tried to avoid over-reaching into subject matters in which we are not knowledge experts (nuclear power, climate change) even though we may have strong opinions.
- We carefully fact check all our arguments. We are not perfect in this regard but we do try to ensure all our arguments are fully supported by facts.
- We always try to be respectful.
- We argue for what is in the best interests of our customers and not what is best for NOTL Hydro.
NOTL Hydro’s advocacy takes many forms.
- We issue press releases. There have been over a dozen press releases over the years that have focused on advocacy issues. Most of these were in 2017 but press releases were made in all years from 2015-2019. These can be found at: https://www.notlhydro.com/news/ and are sorted by year.
- We meet with electricity industry participants and provide our thoughts. Participants we have met over the years have included Ministers of Energy, opposition Energy critics, regulators, government staff officials and other industry participants.
- We submit our thoughts during industry consultations. The Ministry of Energy and the Ontario Energy Board will frequently request input from industry participants as they develop policies and regulations. Most of these are public processes in which anyone can participate though some are restricted to industry participants. In all cases NOTL Hydro can comfortably say that the objective of these consultations is to make the best possible policy or regulation while still achieving the governments objectives. If we can help them find a better way to achieve their objectives, they do listen to us, if we do not like their objectives, not so much.
- We have occasionally intervened in Ontario Energy Board hearings. These take time and can be costly so this is not done lightly. One occasion was the Hydro One purchase of Norfolk Power in which we argued that Hydro One would want to raise the rates so this was not in the interest of Norfolk Power ratepayers. The acquisition was approved but, seven years later, the Ontario Energy Board is trying to deal with the rates issue. Another was the application by the Smart Meter Entity for new rates. The rates were reduced but we would like to see them eliminated.
- We have continuing dialogues with many other electrical utilities. Many small utilities like NOTL Hydro are part of an association called Cornerstone Hydro Electric Concepts (CHEC). As we all face similar issues, we are able to work together and make our positions known in collaboration.
It is impossible to know if our advocacy efforts have had any impact or not. We believe they have but that could just be hubris. The efforts have certainly raised the profile of Niagara-on-the-Lake Hydro within the industry. Many of our recommendations have been ignored (break up Hydro One, eliminate the MDM/R) but many have also been implemented wholly or partly (stop issuing FIT and MicroFIT contracts, eliminate CDM, move the costs of the Green Energy Act to the taxpayer). We fully acknowledge that these actions would have happened anyway but we cannot but help thinking that our advocacy efforts helped move them forward a little.