SCAN!’s Ford’s Bad Energy Choices Campaign (FBEC) has a working group on the Ford government’s rush to pass legislation, Bill 165, to overturn the Ontario Energy Board’s recent decision on Enbridge’s rate application  – a decision that would stop Enbridge from amortizing over a forty-year period the cost of hooking up new homebuyers to their gas network.  The OEB decision would also require Enbridge to take the transition to low carbon energy sources into account when proposing to build out their gas pipeline service network to avoid the danger of having more Ontario residents pay for and be locked in to stranded assets.  FBEC asked SCAN! members to submit written comments on the legislation being rushed through the legislature this month to the Interior Committee now reviewing it.  Gail Greer responded with the submission below.

April 4, 2024

Thushitha Kobikrishna, Committee Clerk

Standing Committee on the Interior,

Whitney Block, Room 1405,

99 Wellesley Street W., Toronto, ON.  M7A 1A2


Re: Bill 165, Keeping Energy Costs Down Act, 2024

Mr. Babikian, MPP, Chair, and Members of the Standing Committee on the Interior.

The Province of Ontario has been my home for close to 84 years. I am deeply committed to the well being of its residents, my family, friends, and their offspring and to its wonderful but increasingly polluted and endangered land, waters, and air. It is with alarm that I see our livelihoods, environment and democracy undermined by ill-informed, arbitrary, authoritarian legislation such as Bill 165. Its title ‘Keeping Energy Costs Down’ and stated goals (bulleted and addressed below) are subverted by its provisions, including the accompanying amendments to the Ontario Energy Board Act.

  • Protect future homebuyers and promote affordable housing.
  • Maintain customer choice with respect to energy options for homes and businesses.

Bill 165 would restore the right of the Enbridge natural gas energy monopoly in Ontario to amortize residential hookup costs to customers over a 40 year period (the revenue horizon) to ‘keep energy costs down’. Housing contractors therefore install hookups in new homes at no cost themselves, locking homeowners into Enbridge’s natural gas service monopoly for years. It is a business model the OEB correctly sees as  becoming obsolete in the face of cheaper, low carbon energy options. Consumers who can afford the up-front cost will purchase low carbon alternatives like electric heat pumps for the energy cost savings, for their own health and to mitigate the impacts of global warming – such as the Derecho that swept across Ontario in 2022, killing twelve people. As more people leave Enbridge’s natural gas system, turning it into a stranded asset, it will become more expensive for those trapped in it –  and for all Ontario taxpayers as your government continues to subsidize Enbridge’s pipeline infrastructure.

You give no consideration to the increase in GHG emissions caused by hooking up the1.5 million new homes you’re planning to natural gas.  When that methane is burned it is a major source of particulate and atmospheric pollution that carries health, infrastructure, and environmental costs. That is an abrogation of your mandate to govern in the interests of the people of Ontario, granted, need you be reminded, by just 18% of the electorate.  According to a recent poll for The Trillium, even a majority of your voters now doubt you are acting in their interest.

  • Ensure fair and informed hearings at the Ontario Energy Board.
  • Ensure Government sets energy policy, not the regulator.

The OEB, charged with protecting the interests of  consumers from the power of a monopoly service provider, took months to do the research, listen to expert advice and to stakeholders. Enbridge had every opportunity to defend its extensive application. The OEB wisely decided Enbridge must start adapting to an evolving stranded asset reality and issued decisions to protect customers from those future costs. That was not setting provincial energy policy but fulfilling its mandate. Bill165 replaces the OEB’s careful informed, highly technical decisions with those of  the Minister of Energy (and Cabinet), politicians with neither the expertise nor the time to understand energy systems, platform service monopolies, the dynamics of evolving economies, or the existential crisis of climate change. Yet Bill 165 allows you to dictate when and why the OEB must meet, whether pipelines can be installed and their revenue horizon. Finally, you stipulate that the actions you take are ‘not subject to any duties of procedural fairness’!

Your government is abrogating a well established tradition within democracies of relying on regulatory bodies to specify policy details that protect the public interest. Independence from political influence is critical to that work.  If you remove it, you will subject Ontario’s 3.8 million gas utility customers to dictatorial political whiplash.

I strongly urge you to abandon this legislation. Enbridge is a large multinational corporation running a privileged monopoly and has the resources to manage the coming transition to low carbon sources of energy. It can take care of itself without your helping hand. Bill 165 does not serve the interests of  the people of Ontario or keep energy costs down. Just the opposite.

Gail Greer, Ph.D., 

Sociologist and Environmentalist.

Seniors for Climate Action Now!


Gail Greer is a Sociologist, former personal investment manager, a member of SCAN!’s Education and Campaign and Platform Committees, and a member of OCEC Connections editorial board.

SCAN! welcomes comment and feedback. Please send your response to The SCAN! blog is managed by the Education Committee, and the Committee is looking for new members. If you are interested in working with a talented and dynamic group of seniors with a focus on information sharing and knowledge management, please contact Martin Bush at the email address shown above.