Submissions to the Electricity Commission
These submissions have been made in response to consultation papers published by the Electricity Commission. You can view the consultation papers on the Commission'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 in detail on the discussion document and answered the Commission’s specific questions
-
recommended that the Commission advise the Electricity Authority that no evidence existed to suggest that the variety of distribution pricing structures and use of system business rules represented material problems that would require changes to the code as anticipated by clause 45(2)(e) of the Electricity Industry Bill
-
recommended that after the Commission advised the Electricity Authority as detailed above, this workstream should be terminated.
Summary
In this submission we:
- noted that the Commission’s proposal seemed workable, at least for a small number of large direct connected customers, although it could not be readily extended to dispatchable demand within ‘shared’ GXPs or balancing areas
- acknowledged that smaller users would struggle to meet all of the participation requirements, even if arrangements with intermediaries were used
- expressed our concern that the proposal did not explicitly address the important coordination issues that would need to be considered to ensure system security
- reminded the Commission that significant demand side participation occurs outside the wholesale market context, and its interaction with dispatchable demand (and wider forms of demand response) needed to be considered
- urged the Commission to consider the possible impact of the proposal, and other demand-side proposals, on the wider stability and coordination of the electricity supply chain
- suggested that before the proposal was progressed further, it might be prudent to conduct a trial with likely participants to establish initial interest, levels of capability, and test the response process in a controlled situation
- provided responses to the Commission’s specific questions.
Summary
In this submission we:
- expressed our concern that the consultation paper lacked a clear context and sufficient detail
- noted our confusion over the paper’s unclear definition of “islanded”
- commented on the cost/benefit analysis and concluded that what really mattered was whether islanding was judged to have a material impact on investment decisions in areas prone to islanding, and whether the consequences of that would be likely to feed through to consumer prices and/or quality of supply
- considered that the proposed solution was workable, and suggested some possible adjustments.
Summary
In this submission we:
- commented that there was no clear rationale for all of the proposed changes to the guidelines
- noted that some aspects of the guideline changes were so broad as to be unworkable
- agreed that it was imperative for distributors to be consulted at an early stage by AMI system providers when they were considering installation or replacement of systems, however given that the AMI implementations on each network would likely be substantially similar, it would not be sensible to require consultation with all distributors for every implementation
- struggled to see why the guidelines needed to specify the circumstances in which advanced meters should be replaced
- concluded that the Commission should consider the proposed changes to the guidelines in terms of whether they would be an appropriate response to an actual problem
- provided comments on some of the proposed drafting changes and responses to the Commission’s specific questions.
Summary
In this submission we:
- considered that the Commission’s proposed approach – of specifying certain principles and minimum terms and conditions, and monitoring and reporting against those – represented a reasonable balance of the GPS requirements and the observation that most existing contracts aligned well with reasonable consumer expectations
- commented on the extent to which the reasonable consumer expectations identified were actually consumer expectations of retailers and, if they were, whether the Commission needed to do anything about them
- questioned whether, if the Commission chose to act, the consumer contract would be the appropriate regulatory instrument
- suggested an alternative to (or an addition to) the proposed approach for intervention in this area – specifically the idea of a consumer charter
- provided detailed responses to the Commission’s specific questions.
Archived submissions
View Orion's archived Electricity Commission submissions for 2006, 2007, 2008 and 2009.
You can also view submissions to the:
|