Other Comments
Other comments on the 2013 review
National Institute of Water and Atmospheric Research (NIWA)
Points out that there is a section of economically robust receivers of the cross-subsidy, and groups not connected. Paper fails to consider DG growth.
David MacClement
Focus on a small minority of users but steps taken should fit in with a much longer plan to enable the electricity and heat supply to be much more resilient, into a future with more natural disasters and other supply interruptions than we have experienced to date.
Major Electricity Users Group
The obvious option that s62 should stand needs to be considered and is a requirement for the Regulatory Impact Assessment. All options other than F should be further considered.
Department of Building and Housing
Department of Building and Housing has set quality targets for housing "quality targets for heating, hot water, cooking and artificial lighting…must have a safe and functional energy source to operate properly". Target suggests line supply will be main delivery, but it is clear that any source is acceptable.
Sian Smith
What will happen to those on low-use tariff in an urban street if obligation expires?
Fonterra
Whatever options are progressed from this review, there must not be any compromise to security and reliability of supply. Any reduction of supply for remote rural users will have flow-on impacts for the economy. Information gaps re specific locations and consumers affected is a barrier to more detailed comment an engagement on issues. Encourages the Government to consider establishing pilot projects.
New Zealand Police
NZ Police are concerned that the removal of uneconomic lines will affect their ability to deliver the same standard of policing they do at present. Communications services could be degraded.
Ontrack
Ontrack concerned that a removal of uneconomic lines involving the removal of reliable power supplies in remote areas will affect ability to provide safe and economic operation on sections of the national rail network. Needed for railway signalling, level crossing alarm systems and train control repeater sites. Alternative technologies are currently not practicably capable of providing an equivalent reliable supply.
TelstraClear
Civil Defence Emergency Act states "the economic vitality of communities and of the nation as a whole depends upon the continued operation of lifeline utilities". Primary amongst those are telecommunications facilities.
JDA & Associates
Civil Defence Emergency Act states "the economic vitality of communities and of the nation as a whole depends upon the continued operation of lifeline utilities". Primary amongst those are telecommunications facilities.
Vodafone
Civil Defence Emergency Act states "the economic vitality of communities and of the nation as a whole depends upon the continued operation of lifeline utilities". Primary amongst those are telecommunications facilities.
Unison
Review of EIRA needs to take account of both current obligation and any intended extension of obligation.
Unison
Further review and consideration of resulting implications needs to be undertaken before a decision can be made. The formation of a working group by MED for this purpose would provide an appropriate forum.
Marlborough Lines
In event line becomes redundant, consideration should be given to need for removal of that line, and if not removed, any liabilities arising from an incident caused by that line. Cost of removal of a line is significantly higher than the value of any re-usable materials recovered. Discontinuation will result in a need for the lines company to maintain a redundant line to a "safe" standard or meet significant costs to remove that line. This aspect should be taken into account in the review.
Marlborough Lines
If the outcome is that cross-subsidies are to continue or increase over time, there is a case for re-introduction of franchise areas. Otherwise the "incumbent" network will be placed in an impossible position vis-à-vis other potential network owners who are not required to subsidise remote lines in that region.
Marlborough Lines
Following analysis of submissions, the Ministry should seek further input from consumer groups and lines companies prior to finalising any recommendations to the Minister. It may be appropriate for the Ministry to form a working group to further discuss options and alternatives available. We believe there is adequate time to allow such steps given the more than 5 years before the relevant section of the Act comes into force.
Network Tasman
Under ongoing obligation for continuance, it is imperative that periodic reviews are scheduled to ensure this remains good policy in light of changing technologies, changing relative costs and condition of ageing infrastructure.
Top Energy
Continues to construct supply lines and connect new consumers where cost of new connection means is uneconomic. Operates a capital contribution scheme where consumer funds uneconomic proportion of equipment, refundable when additional consumers connect. No undertaking to maintain supply for a period of time – presumed when required to be replaced consumer will again part-fund.
The Lines Company
Distributed Generation Regulations oblige us to provide line services to DG at marginal cost, which will exacerbate uneconomic lines issue. The company will receive little extra income from DG and to the extent consumers save on line charges, income is likely to decrease from these lines rather than increase.
Counties Power
Ownership and access rights often unclear, there will be consumers who lose supply, or whose supply is threatened, not because of a decision by a lines company to disinvest, but because of unclear ownership and access issues.
Collective submission - 18 lines companies
Review should be completed taking into account other policies and legislation including
- Low fixed charge tariff option
- Arrangements for low income domestic consumers
- Relativities between rural and urban line charges
- Model approaches to distribution pricing
- Arrangements for connecting distributed generation to distribution networks
- Model Use-of-System Agreements between retailers and distributors
- Part 4A pricing methodologies and allowable cross-subsidies.
Electricity Networks Association
Review needs to be continued and consider full issues identified in ToR and other important concerns identified. Work needs to be done to address the problems of electricity supply to remote consumers positively, rather than simply relying on the extension of section 62. ENA would like MED to form a working group for this purpose, which would include ENA and other public and private stakeholders, including Federated Farmers to ensure that remote consumers have the most efficient, reliable and environmentally sustainable electricity supply.
Electricity Networks Association
Important for MED to provide analysis as to the extent of other statutory obligations to service "remote communities" or to provide uneconomic services, as well as different government solutions to each of these situations. Appropriate for electricity lines sector to be treated neutrally, even if in a different way, in relation to other infrastructure sectors.
Vector
Endorses ENA's submission for a stakeholder group to be convened to further develop an appropriate policy.
Vector
If continuance of supply by lines or alternatives imposed on lines companies, necessary to reconsider limitations placed by EIRA. In transition period between lines and alternatives, lines businesses may supply by a combination of old lines and new supplies until the old lines fail and are permanently retired.
Powerco
Impacts of wider context need to be explicitly acknowledged and where appropriate built into decision-making process. Discussion paper states it takes into account NZES and EIRA but it is not immediately evident where and how these matters have been considered.
Network Waitaki
Under existing legislation line companies only have an obligation to provide Line Function Services up to the consumers Point of Supply (POS). The consumer is responsible for the service line they own between the POS and their installation. This can represent a substantial amount of asset. If there is an issue of economics then it is the service line that will be biggest driver of any decision by the consumer to continue taking supply.
NWL maintains that for practical purposes "Continuance of Supply" means so long as the consumer wants the supply and is prepared to pay the economic cost. The requirement is a "smoke and mirror" political ruse.
By 2013 this situation will have been the case for 20 years and there has not been widespread disconnection of uneconomic supply. When a line is in need of major replacement (and the service lines will always come up first) consumers are given appropriate advice and they decide whether or not they will continue with supply. Because the line company knows what condition a line is in, it will give a consumer plenty of notice to minimise upset and will try to give advice when the issue can be managed at least cost. There is no upside for line companies in aggravating consumers in the way it manages assets.
Meridian
One of the implications of lines companies assisting transition from LFS, if this option involves lines companies purchasing generation equipment for rural consumers, and retailing electricity, will be the need for officials to monitor the level of retailing by lines companies to ensure this activity is compliant with EIRA.
Environment Waikato
Paper makes no mention of appeal or arbitration for lines companies unhappy with the "deal" offered by lines companies. Suggests Ombudsman function. Also suggests using the term "energy services".
Marlborough District Council
Need to know the extent of cross-subsidy as can't have a meaningful discussion of section 62 except in very broad principle based terms.
Northland District Health Board
Concerned that it was not contacted to make a submission on the issue as it might have adverse public health impacts. Northland is one of the most deprived areas in the country 49% in lowest deciles (NZ 30%) of which 78% Maori. 6% of population live in remote rural compared with 2% nationally. Should do a health impact assessment
Southland DC
User pays notion should not be pursued at all. Efficiency does not always promote a better allocation of resources… real risk of compromising the economic, social and cultural well-being of rural communities.
Ruapehu DC
Contribution of agriculture to NZ's economy has been rising. If other method of supping energy are more cost-efficient and fair (i.e. does not penalise consumer by way of affordability or quality of life) then should be considered.
Local Government NZ
Time to consider document relatively short – insufficient time to get sign-off from elected members in Local Government, and the National Council. Options weren't assessed against proposed criteria – only impacts were considered. Electricity is a public as well as private good. Incentives to develop alternatives required; consumer choice in delivery. Options a,b and f to given further consideration.
Far North District Council
Far North District Council had 5 customers per kilometre; not many other Districts in NZ with such constraints from terrain and population dispersal. Wants a new funding pool to assist in new lines build so that consumers are not taking risks with candles (five years, seven deaths from house fires attributed to candle use).
Environment Bay of Plenty
Support a consultative and co-ordinated process for any changes to supply for affected electricity consumers; changes based on alternative supply agreed before change occurs; encourage renewable energy generation wherever possible. Guidelines for consulting on intended changes to line supply. Connections to NZ strategy need to be made.
Ruapehu DC, Otorohanga DC, Waitomo DC and The Lines Company
For predominately rural communities with no major metropolitan network the major replacement of lines will create a considerable burden on the region. Government funds roads nationally, should fund electricity. Boundaries of the network companies are artificial for the purpose of establishing catchments for funding remote lines.
Te Aroha Kanarahi Trust
Lines companies have an obligation to assist communities with education to reduce energy consumption through transition; provide financial support to offset capital costs; tailored research to families; provide lists of reputable suppliers; ensure rights of current customers are protected.
Mighty River Power
The combination of an obligation to supply and the ODV requirement means that the costs of doing so are borne by line company shareholders. Recovery of the cost of uneconomic assets will show up as excessive profits under Electricity Information Disclosure. MED need to analyse policy with Commerce Act. True cost of uneconomic supply should be identified in Electricity Disclosure regime.
Watercare Services
Revision to s62 to include definition of uneconomic. Transitional arrangements "in sufficient time". Change does not reduce level of service.
Telecom
Clear definition of uneconomic is needed to be able to determine extent of those affected. Urban consumers benefit from remote telecommunications site on sparely populated hill tops. Conflict between removal of section 62 and Civil Defence Emergency Act. Principles for review are clarity, technological neutrality, competitive neutrality, minimise uncertainty.
MC and AE Ward
Power lines have always crossed rural areas in order to supply urban areas. Perceived subsidy of urban to rural is more than offset by the use of rural land to supply access for power lines serving urban areas.
Theodora C Ward
Contribute to provision of electricity by having pylons on land. Demand for power to rural increases.
Anthea Ward
A good electricity supply is a great factor in keeping rural workers in remote places; without electricity for modern conveniences there would be a rapid drift to urban areas.
Back to Top