| Submission |
Officials' Response |
| Para 51 – KCE – Support for renewable energy generically is positive, but hydroelectricity appears to be second class. |
Noted – section does not favour any particular type of renewables. |
| Para 52 – Vector, Meridian – specification of grid planning processes and approval criteria should not unduly favour grid upgrade plans that facilitate development of 'renewable generation' over grid upgrades for security of supply. The transmission framework should promote optimal transmission investment. |
Noted – No change. Security of supply objectives are included in the GPS at paragraph 55 (now 52), and do not indicate that renewables are favoured over security of supply. |
| Para 52 – Electricity Networks Association – suggest an additional bullet "Transmission pricing methodologies, especially for new or renewed grid investment, should ensure that loads including generation receive real locational signals." |
No change – this is covered in other parts of the GPS (paragraphs 89 and 111-112, now 83 and 105-106) regarding transmission alternatives. |
| Para 52 – MEUG – Bullets 3 and 4 need to reflect balancing of facilitating renewables while achieving the other objectives of s172N of the Act. |
Noted – No change. The Act requires the GPS to be consistent and the EC must balance facilitation of renewables with other objectives. This does not need to be stated in the GPS. |
| Para 52 – IPENZ – Supports objectives |
Noted. |
| Para 52 – MRP – the third and fourth bullet points appear to be saying the same thing. |
No change – although the bullets are similar, one is about Transpower planning and one is about EC processes. Having 2 bullets reinforces the different roles between the two agencies. |
| Para 52, 4th bullet – Transpower – Some rule changes may be required to achieve this objective. Recommends adding to the fourth bullet in para 52 'The Commission should recommend any Electricity Governance Rule changes that are necessary to achieve this. ' |
No change – The Commission will develop rules, if necessary to support objectives and outcomes through many sections of the GPS. Rules and Regulations addressed in paragraphs 3-4. |
| Para 52, 4th Bullet – Genesis – it is not necessarily the case that there is a mis-match between transmission and generation lead times and that this problem is enduring. Suggests either the last part of the final bullet point is deleted, or adding 'where this has been demonstrated to be tangible, enduring problem'. |
Agree – redrafted to refer to 'any' difference in lead times for transmission and generation investment. |
| Para 53 – ENA, Transpower – ENA suggests the first sentence should include "without unreasonably compromising electricity security of supply." Transpower notes 90% renewable generation target should be consistent with the Government's key requirements for security of supply and recommends adding to the final bullet point in paragraph 52: "…and the need to maintain adequacy, reliability, security and quality of supply (in particular voltage support, frequency stability and overall system stability)" |
No change – security of supply objectives are included in the GPS at in paragraph 55 and do not indicate that renewables are favoured over security of supply. |
| Para 53 – Contact – supports the specific treatment of wind integration issues and believes the EC has to date played a positive role in investigating the role of wind in the NZ electricity market. |
Noted. |
| Para 53 – IPENZ – Support, but suggest marine-derived energy conversion should be specifically included due to its potential. |
No change – focus of paragraph relates to intermittent wind generation (which is more likely in the near term than marine). |
| Para 53 – MRP – Heading above should be 'wind integration issues'. |
No change – detail is outlined in paragraph 53 (now 50). |
| Para 53 – MRP – Jumps straight to prescribing a solution. An approach more consistent with the statutory framework would be to specify the government want the Commission to use its powers and functions to ensure the maximum economic potential of wind generation can be achieved, leaving it up to the Commission to decide how to do this. |
Noted |
| Para 53 – Genesis – First sentence revised to 'The Commission should…', rather than 'The Government expects the Commission to…'. |
Agree – text has been changed. |