| Submission |
Officials' Response |
General – Meridian, Contact
Supports the consumer protection measures in GPS |
Noted. |
Para 16 – Powerco
Recognises need for consumer contracts to "reflect the reasonable expectations of consumers", but believes retailers and distributors should also have some protection. Proposes additional words "and are not unduly onerous for electricity retailers and distributors." |
Not necessary. EC has to follow good process, assess the costs and benefits of proposals and consult with affected parties. |
Paragraphs 19 and 20 – Orion
Question the need for the EC to carry out both a monitoring role and development of model contracts and proposes that the requirement for EC to continue to develop model consumer contracts be removed. |
Paragraphs 19 and 20 duplicate information and should be combined. Do not agree that the requirement for the EC to continue to develop model domestic contracts should be removed. Model contract should evolve to reflect changing market issues. |
Para 21 – ENA
The word "unreasonably" should be removed from the reference to fixed daily charges prior to introduction of the regulations. |
Noted - the drafting reflects government policy at the time the regulations were introduced. |
Para 23 – MRP
Proposes that monitoring compliance with guidelines and recommending regulations if necessary, and specifying in detail what regulations should consist of, is too prescriptive. Instead EC should monitor compliance and consider alternative options if non-compliance is an issue. |
Noted. However approach in GPS is consistent with government policy. |
Para 23 – KCE
Requirements relating to low income and vulnerable consumers are social responsibility goals that should be covered by the government and not passed to companies to carry the social load. |
Noted. |
Para 24 – KCE
Limiting bonds to 1 month is inadequate as arrangements in para 23 can take up to 7 weeks. |
Noted. |
Para 27 – KCE
Complaints system should apply only in situations where there is a commercial relationship because otherwise how can a company be held responsible. |
Disagree. Not all potential complainants are in a commercial relationship with the company they are in dispute with (e.g. a potential customer). |
Para 27, 31 and 32 – ENA
References to "all distributors (including Transpower)"should be altered to "all distributors and Transpower" because the designation of Transpower as a distributor is misleading. |
Transpower distributes electricity. The terminology used does not create any confusion. |
Para 29 – EGCC, Commerce Commission
Supports proposal for single scheme and endorses the international benchmarks in para 32 (EGCC). |
Noted. |
KCE – Para 29
A single scheme disadvantages consumers currently covered by the independent scheme set up by KCE. |
Noted. |
Para 26-32 – Meridian
These paragraphs do not recognise the Commission decision to only approve one scheme. |
Noted. GPS is statement of government policy and policy is for there to be only one scheme, and this is set out in paragraphs 29 and 30. |