Other submissions
A short summary of miscellaneous submissions is provided below. The full documents (PDF files) can be viewed using Adobe Acrobat Reader.
Summary
In this submission to the Ministry of Consumer Affairs we:
- disagreed with the reasoning in the paper and the paper’s recommendations
- emphasised that the Consumer Guarantees Act does not work for electricity as a good and should be changed so that liabilities apply only when the service has not been provided to an acceptable quality (being the existing reasonable skill and care test).
Summary
In this submission to the Ministry of Consumer Affairs we:
- provided our view on whether the Consumer Guarantees Act should be amended so that both an electricity retailer and a lines company would be liable for the quality guarantees set out in the Act
- did not think it appropriate that the Ministry propose amendments to the Act merely to cast a wider net or simply require both parties to be liable, rather it needed to clearly establish what each party would appropriately be liable for
- concluded that the Ministry should move to have the Act amended, however any amendment needed to reflect an in-depth review of the application of the Act to electricity since 2003
- provided a detailed legal review of the application of the Act to electricity.
Summary
In this submission to the Finance and Expenditure Select Committee we:
- supported many of the objectives of the Bill, while strongly disagreeing with some aspects of the proposals
- noted that the impact of the Bill on perceived problems was at best uncertain and that, in particular, the likelihood of the Bill resulting in increased competition outside the main centres was doubtful
- recommended that new requirements to standardise distribution pricing be removed from the Bill
- recommended that new requirements to prohibit distributor related retailers from purchasing customers from existing retailers be removed from the Bill
- suggested that consideration be given to removing several other proposed requirements, and that some functions be transferred to the Commerce Commission (where relevant) to avoid regulatory overlap
- recommended that the thresholds above which Part 3 would apply to distributor involvement in generation and retailing should be increased
- commented that physical asset swaps were unnecessary and that, while virtual swaps might lead to significant customer churn between SOE retailers, this would not necessarily improve competition outside main centres and could discourage entry and competitive activity by non-SOEs, therefore the swaps should be abandoned
- supported the establishment of the Electricity Authority, with a minor change to levy arrangements.
Archived submissions
View Orion's archived other submissions for 2006, 2007, 2008 and 2009.
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