Since 2013, Payment Compliance Initiatives (which offer an incentive for early bill payment and an equivalent penalty for late payment) have been introduced by both the Jamaica Public Service Company Limited (JPS) and the National Water Commission (NWC). In their submissions to the Office of Utilities Regulation (Office/OUR), both utility providers highlighted the adverse financial impact of late payments on their operations. The OUR was therefore requested to approve Early Payment Incentive/Late Payment Fee (EPI/LPF) programmes, which is intended to encourage the payment of bills on, or before the due dates.
The Office approved JPS’ proposal in the Jamaica Public Service Company Limited Annual Tariff Adjustment for 2013 – Determination Notice (Document No. 2013/ELE/007/DET.001) dated 2013 June 25 and NWC’s proposal in the Determination Notice entitled National Water Commission – Payment Compliance Initiative (Document No. 2015/WAS/003/DET.001) dated 2015 July 28. However, subsequent to the implementation of these initiatives, the OUR, through its Consumer Affairs Unit (CAU), has received complaints from JPS and NWC customers disputing the reasonableness of the fee. Among the complainants were pensioners, who lamented that their due dates for payment of bills preceded the receipt of their monthly pension payments. Accordingly, where they are unable to make their payments on or before the due dates, they will incur LPFs, which in their view, is an unreasonable additional charge.
Having reviewed the issues raised by pensioners, the OUR has also considered that another group of utility customers – namely, Persons with Disabilities (PWDs) – may also be adversely impacted by any additional charges, including the LPF.
In keeping with the provisions of Condition 16(1) of the Electricity Licence, 2016 and section 4(2)(a) of the Office of Utilities Regulation Act (OUR Act), and given the economic position of most pensioners and PWDs (together referred to as vulnerable customers), the OUR thought it necessary to conduct this consultation to ascertain whether these customers should be offered the choice to opt out of the EPI/LPF programmes. By so doing, those vulnerable customers who chose to opt out of the EPI/LPF programmes would not be eligible for the EPI or would be billed the LPF.