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Consultation Documents_Opt-out EPI_LPF Vulnerable_Utility_Customers (Public Version)

Consultation Documents_Opt-out EPI_LPF Vulnerable_Utility_Customers (Public Version)

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.

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