| Submission |
Officials' Response |
Para 126 – MRP – Clarify what objectives and outcomes the government wants the Commission to achieve. Is the desired outcome the removal of barriers to the development of distributed generation, should this prove necessary?
|
Agree that a definition of DG is not required in this paragraph. 1st sentence has been deleted. The reason for the focus on DG is articulated at the end of the paragraph. |
| Para 126 – Genesis - suggest delete first sentence and go straight to second i.e. ‘Distributed generation is expected to play…' |
See comment above. |
| Para 127 – Genesis – suggests deleting detail on what regulations cover. |
Agree - processes in regulations do not need to be outlined in GPS. Text revised. |
| Para 127 – Odyssey – The current regulations allow network companies to turn down a connection application when that application causes technical problems that a ‘prudent' network operator finds unacceptable. It may be necessary to define in legislation when a network has reached capacity based on it ability to ensure adequate quality of supply without exceeding appropriate network loss benchmarks. |
Noted. Comments on regulations are outside of the scope of the GPS. |
Para 128 – Genesis – suggests the following revisions: "The Commission should ensure that, where possible, regulatory compliance costs associated with the Regulations are minimised and the safety of connections to local networks are improved. The Commission should also seek to ensure that access to lines by retailers are not compromised by any changes made to the Electricity Industry Reform Act to facilitate the increased involvement of lines companies in retail
and generation." |
No change - paragraph reflects government policy as outlined in the NZEECS. Issues in relation to access to lines are covered in para 119 relating to use of system agreements. |
| Para 128 – Odessey – We recommend the use of national guidelines and standards that will ensure they are common throughout the country. |
Noted – paragraph reflects Government policy as outlined in the NZEECS. |
| Para 129 –ENA - should include reference to other buyers as well as retailers. It would seem reasonable to provide for purchases from generators by, for example, end users where this is commercially realistic. |
No change – terms and conditions are for purchase of electricity from household scale generators, who are likely only to sell to retailers, rather than participating in the market. |
| Para 129 – Genesis – rather than simply requiring the EC to ensure contracts include reasonable terms and conditions, the EC is to investigate and make recommendations on specific issues outlined in the bullet points. This goes beyond section 172O(1)(i) of the Act. Suggest deleting the last sentence and 2 bullet points in this para. |
No change – paragraph reflects government policy as outlined in the NZEECS. |
| Para 129 – Odessey – If distributed generation is to make a significant contribution to the NZES, then many proposals need the certainty of a minimum return on exported electricity. Possibly all large retailers should be required to include a minimum return for electricity provided from distributed generators with their tariffs unless that generator opts out. We believe the proposed model contracts should be considered as the ‘opt out' option when ultimately developed. |
Noted. Model contracts have been developed and a copy can be found on the EC website. Paragraph reflects government policy as outlined in the NZEECS. |
| Orion – recommend a requirement in relation to the purchase of small amounts of excess generation be added to the list of issues in para 17 of the GPS that the Commission is required to ensure is included in contracts. Paras 129-133 could then be deleted. |
No change – Government's objectives/policy for DG are broader than consumer protection issues. |
| IPENZ – Important that appropriate specifications and standards are put in place in the regulations to ensure that small generators are clear about what is expected of them, and that the technical requirements are not set unreasonably high with the result of excluding them. |
Noted – outside scope. Regulations are already in place. Work outlined in NZEECS will address this issue. |