Submissions to the Electricity Authority
These submissions have been made in response to consultation papers published by the Electricity Authority. You can view the consultation papers on the Authority'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:
- commented on the pre-consultation: connection of distributed generation consultation paper
- commented on the Authority’s proposals and suggested additional proposals that the Authority may wish to include for consultation.
Summary
In this submission we:
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commented on the part 10 review – proposed amendment to the code consultation paper
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noted our disappointment that the Authority declined our request for an extension of the consultation paper
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congratulated the Authority on making significant changes in response to earlier submissions and deferring some areas of the current consultation to a later stage
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reconfirm that we support the proposal that a review of the rules in Part 10 is required; however careful consideration must be given to this difficult area of the rules
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responded to specific questions set by the Authority.
Summary
In this submission we:
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commented on the criteria for assessing alignment against information disclosure guidelines and pricing principles consultation paper and the companion Concept Consulting report
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support the principles-based approach to the regulation of distributor pricing backed up by information disclosure and welcome the continued endorsement of the approach
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strongly agree with the recommendation in the Concept report that the Authority work with the Commerce Commission to ensure that only one pricing disclosure is required and the regulatory approaches and requirements are aligned
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urge the Authority to acknowledge that a principles-based / disclosure approach is of necessity a medium to long term instrument
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consider that in some respects, the paper (and the Concept report) expect more of the methodologies that is reasonable
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responded to specific questions set by the Authority.
Summary
In this submission we:
- commented on the standardisation: clarifications to prudential proposal and proposed changes to distributor indemnity proposal consultation paper
- reconfirmed that we do not consider it appropriate for the Authority to draft code prior to it making a final decision on policy matters
- responded to specific questions set by the Authority.
Summary
In this submission we:
- commented on the standardisation: model use-of-system agreements and proposed code amendments consultation paper and the various companion documents
- confirmed that we believe the Authority should consult on the policy issues first
- confirmed that we agree with the ENA’s recommendation that the Authority establish a technical working group to undertake the redrafting of the MUoSA following policy decisions
- confirmed that we do not agree with the Authority’s proposal to extend the scope of liabilities by widening the definition of direct loss Clause 5.1.95 of the paper
- confirmed that we do not agree with the Authority’s proposal that the limitation of liability for a single event or a series of events or circumstances should be set at an amount equal to 50% of the total line function services charges payable by the retailer to the distributor in the 12 months prior to the occurrence of the event or the series of events
- confirmed that we do not agree with the Authority’s position on property rights for load management
- responded to specific questions set by the Authority.
Summary
In this submission we:
- commented on the standardisation: model use-of-system agreements and proposed code amendments consultation paper
- confirmed that we support the conclusions and recommendations in the ENA submission
- noted that the paper lacks a principled basis for many of its proposals and has not adequately considered the possible unintended consequences of regulation
- responded to specific questions set by the Authority.
Summary
In this submission we:
- commented on the dispatchable demand consultation paper
- recommended that the Authority limits the scope of the proposal to just a few major customers and takes careful note of the existing load management initiatives before proceeding beyond this stage
- recommended that the Authority examines the role of the distributor as an aggregator and co-ordinator of load – a local system operator – to manage the balancing of supply and demand at a local and regional level
- responded to specific questions set by the Authority.
Summary
In this submission we:
- commented on the demand-side bidding and forecasting consultation paper
- confirmed our support of the move to centralised forecasting as we have no doubt that it will improve the accuracy of scheduling and associated indicative prices
- noted the importance of a central demand forecast to recognise the coordinated load management, if it is to be as accurate as possible
- noted that the paper has not discussed the implications of coordinated load management, which we believe to be a worrying oversight
- noted that the paper does not appear to have considered the implications of any decentralised demand response on system stability and in particular the implications of restoration of demand
- confirmed that we would like to meet with the Authority to share the learning’s from what is now several years of coordinated load management experience.
Summary
In this submission we:
- commented on the more standardisation of distribution arrangements: proposed amendments to the code consultation paper
- noted that the paper is aimed at making life easier for new entrant retailers rather than the long term interest of consumers
- expressed reservations about the rationale for and the materiality of a number of the proposals
- strongly recommend that the Authority ceases working on some of the proposals
- responded to specific questions set by the Authority.
Summary
In this submission we:
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commented on the advanced metering infrastructure nomination of the MEP and access to data consultation paper
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noted our significant concern that we cannot understand the proposal or see how it would work in practice
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suggested that the Authority “does nothing” as the paper has failed to articulate the problem that needs to be solved
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responded to specific questions set by the Authority.
Summary
In this submission we:
- commented on the customer compensation scheme – mandatory default arrangement consultation paper
- recommended that if the Authority is keen to encourage participation by new entrants, it should consider how code changes will impact on the attitude of those entrants who are not closely associated with generators
- suggested that the Authority have confused security of physical supply with its financial consequences
- responded to specific questions set by the Authority.
Summary
In this submission we:
- commented on three consultation papers, specifically: interpretation of the Authority’s statutory objective; consultation charter; and charter about advisory group
- congratulated the Authority on signalling early its intent to consult early, openly and widely noted that it is important for the Authority to start off on the right foot by providing a framework for its activities that address the industry realities and emerging future responsibilities
- recommended that the Authority should emphasise reliability as being what electricity consumers value most, and distributors’ and Transpower’s central role in delivering this
- recommended that the Authority should be very cautious in attempting to regulate those parts of the industry that are already subject to specific regulation by other agencies.
Archived submissions
View Orion's archived Electricity Commission submissions for 2006, 2007, 2008, 2009 and 2010.
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