Submissions to the Ministry of Economic Development
These submissions have been made in response to consultation papers published by the Ministry of Economic Development (MED). You can view the consultation papers on the MED's website.
A short summary of each submission is provided and the full documents (PDF files) can be viewed using Adobe Acrobat Reader.
Summary
In this submission we:
- generally supported the direction of the proposed regulations, however we were concerned that some aspects of the proposals would be unworkable and create unnecessary complexity, confusion and duplication of existing requirements
- emphasised that specifying detailed, prescriptive safety requirements in relation to works was unnecessary, as public safety issues relating to works would generally be identified and managed through audited safety management systems when the regulations came into force
- acknowledged there was a need to outline high level safety requirements for works not covered by safety management systems, however we considered that works in that category should be treated separately in the regulations
- generally supported the Electricity Engineers’ Association’s submission on the proposed regulations
- commented in detail on specific clauses in the proposed regulations.
Summary
In this submission we:
- congratulated the MED for preparing the report across a wide range of issues
- recommended that the reserve energy scheme be phased out to help resolve perverse incentive issues and lead to more prudent risk management
- raised potential issues in relation to both the proposed price floor and the compensation scheme
- agreed that energy efficiency responsibilities should be consolidated with EECA
- welcomed the paper’s favourable assessment of the electricity distribution sector and endorsed the decision to make no recommendations in this area
- agreed that the level of actual and proposed investment in new generation capacity suggests there is no particular concern with medium term generation capability, and noted that ending the reserve energy scheme should make it more likely that investors would build reserve or peaking style plant
- commented in detail on wholesale and retail price issues, and on the MED’s specific recommendations
- urged caution in the selection and timing of recommended actions.
Archived submissions
View Orion's archived Ministry of Economic Development submissions for 2006, 2007 and 2008.
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