| Submission |
Officials' Response |
| Para 120 – ENA, Unison suggest add to the end of the paragraph "It also sets out these expectations in relation to the administration of other electricity industry legislation including the Electricity Industry Reform Act 1998. For the purposes of this Policy Statement bills introduced by the Government and before the House that relate to electricity supply and the regulation of electricity supply and distribution services shall be considered to be indicative of Government policy." |
Noted - the GPS should not be held up pending resolution of other work programmes and will be amended if necessary once work is complete. |
| Para 121 – Genesis - First sentence revised to ‘The Commerce Commission and the Commission should…', rather than ‘The Government expects the Commerce Commission and the Electricity Commission to…'. |
No change. Objective is broader than just EC. |
| Suggested para 123a – ENA, Unison – "The government's Energy Strategy favours the development of local and distributed generation, including investment in such generation by lines businesses". |
Noted – no change. This issue is included under bullet 4 in para 125 as a matter to be addressed in the MoU between the Commissions. It is also covered in section 11, paragraph 126. |
| Para 124 – ENA, Unison, Vector, Orion – suggest references to Part 4A and thresholds should be deleted. |
Agree. |
| Para 125 - Commerce Commission – does not consider 30 June 2008 date is achievable to review MOU. Recommend delaying until 31 March 2009, given delays in the issuance of the GPS, and complexities associated with matters in para 125. |
Agree – revised date included of 30 November 2008, six months from release of revised GPS. |
| Para 125 – Meridian Energy – MoU should be explicit about the role of the two Commissions with respect to EIRA, Information Disclosure Regulations and DG regulations, particularly as they relate to lines business re-entering generation and retail. The EC should monitor the offering (as well as take up) of model use of system agreements, particularly in networks where lines companies are generating less than 10MW in house and not required to have a UoSA. Meridian |
Noted – The GPS can be amended if necessary in response to any changes in EIRA allowing lines companies to generate/retail, once work is completed. |
considers this a matter that the EC and CC must work together on. |
|
| Para 125 – Powerco, Contact – Support improved co-ordination in this area. |
Noted. |
| Para 125 – Genesis – Suggests redrafting of the paragraph, including removal of the specific bullet points. |
No change - bullet points are specific issues of government policy that the MoU should address. |
| IPENZ – The issue of clarification of the role of the EC in relation to other agencies (Commerce Commission, EECA) is not adequately dealt with in the revised GPS, particularly delineating which agency determines policy and which has responsibility for implementation. Effort must be given to addressing this matter to ensure that there is investor confidence that there will be stable and consistent rules for the wholesale electricity market. |
No change – the GPS provides for MoUs to be developed specifically to address these issues. |
| Transpower - Recommends including in the GPS that the Government's expectation is that the MoU will be reviewed to make it consistent with the administrative settlement between Transpower and the Commerce Commission, and with any future amendments to Part 4A of the Commerce Act 1986. |
No change – parties will amend MoU in relation to the first part if necessary. In relation to the second part the GPS should not be held up pending resolution of other work programmes and will be amended if necessary once work is complete. |