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Ontario Access to Natural Gas Act, 2018 (Bill 32)

Proposed Natural Gas Expansion Support Program
Submitted to the Ministry of Energy, Northern Development and Mines

By the Canadian Propane Association
November 30, 2018

Submission Overview

The Canadian Propane Association (CPA) welcomes the opportunity to participate in the consultation on Ontario’s proposed Bill 32, Access to Natural Gas Act, 2018 (Bill 32), authorizing the creation of a rate-payer funded cross-subsidization Natural Gas Expansion Support Program.
The CPA is the national association for Canada’s propane industry. In Ontario, members include producers, wholesalers, transporters, equipment manufacturers, retailers, distributors and associated sectors in financial services.

The CPA works with governments and regulators on policy issues that affect the propane sector, such as providing affordable and low-emission efficient energy to consumers. The CPA provides key services such as an innovative platform for industry members to collaborate on best practices, providing industry training through the Propane Training Institute and emergency response for propane and flammable liquids thorough Emergency Response Assistance Canada.
Approximately 100,000 Ontario households rely on propane as their primary and affordable source of heating fuel. Not only that, propane is also used in commercial, transportation, industrial and agricultural applications all across the province. Almost half - about 45% - of propane used in Canada occurs right here in Ontario.

Many of our members operate family-run businesses in small towns and rural communities across Ontario. They form the very fabric of the communities in which they live. They volunteer their time, donate to local sports teams and most important create good paying local jobs.
Propane is abundant and available now, with over 140 large storage facilities and 817 small storage sites across the province. Propane has the largest network of alternative fueling stations in Ontario, with 100 locations and 1,800 in Canada.

In presenting this submission, the CPA considers the following overarching principle as crucial to developing public policy:

“In all its policy, government must ensure a level playing field – with no exemptions, no exclusions, and all participants treated fairly and equally.”

While CPA members are sure that the intent of your government is to provide Ontarians with real energy choices, the effect of allowing natural gas utilities to subsidize expansion through taxing existing customers, even at a later date, is not a fair market-based approach. Pursuing that course of action amounts to supporting a corporate subsidy that will increase costs in the long run and ultimately will not be financed by private money but rather by Ontario’s natural gas customers. The utilities’ shareholders must pay for the up-front costs before they are to recover their investments through billing existing customers in addition to charging their new customers for the additional costs. Furthermore, clear limits must be set through the regulation.

With this in mind, in order to ensure fairness and to maintain competitiveness, the regulation’s design must be adequate and must safeguard the above-mentioned principle and should be set with clear limits.

For our complete submission, please see https://propane.ca/wp-content/uploads/2018/11/CPA-Submission-Bill-32_On…