Submissions

ENA cross submission to the Energy Competition Task Force about the initiative requiring distributors to pay a rebate when consumers supply electricity at peak times. The submission expresses support for the intent of increasing security of supply and reducing consumer costs through more small-scale solar and battery support but raises concerns about practical implementation, evidence base, and distribution-level impacts.

ENA submission to the Electricity Authority and Energy Competition Task Force about various initiatives concerning distribution pricing and consumer incentives. The submission emphasises the need for a principles-based approach to adapt to evolving market conditions, concerns about regulatory overload, and the necessity for implementing efficient pricing signals for distributed generation to ensure network benefits.

ENA submission to the Electricity Authority about the proposed amendments to connection pricing and processes. The submission highlights concerns over inconsistencies in both these areas and suggests alternative approaches that prioritise industry collaboration and evidence-based policymaking.

ENA submission to the Commerce Commission about aligning the Weighted Average Cost of Capital (WACC) rate to the Default Price-Quality Path (DPP4) rate from 1 April 2025. This alignment is seen as a pragmatic step to reduce the incentives not to apply for Customized Price-Quality Paths (CPPs) due to fears of exposure to different WACC rates.

ENA submission to the Commerce Commission about proposed amendments to input methodologies for electricity distribution businesses and Transpower. The submission discusses issues related to the reopener event allowance, connection pricing, and quality path amendments, emphasizing the need for clarity and alignment with ongoing projects by the Electricity Authority.

ENA submission to the Electricity Authority about the proposed Code amendment for distribution connection pricing. The submission discusses the potential impacts of regulatory changes on pricing methodologies, advocating for principles-based regulation to enhance flexibility and address potential inefficiencies in connection pricing for electricity distribution businesses.

ENA submission to the Electricity Authority about the update to scarcity pricing settings. ENA supports the proposed changes but emphasises the importance of a careful approach to code revisions to not undermine existing systems like hot water load control, which play a critical role in network operations and consumer pricing.

ENA submission to the Commerce Commission about the default price-quality paths for electricity distribution businesses. The submission discusses concerns over proposed revenue smoothing, capital expenditure impacts, and operational changes, urging the Commission to reconsider some proposals to ensure financial stability and minimal consumer disruption.

ENA submission to the Electricity Authority about proposed amendments to the Default Distribution Agreement (DDA). The submission highlights concerns over the new clause 9.10, which aims to exempt consumers from paying for electricity services during interruptions, arguing it could counter the Authority’s statutory objectives by failing to enhance competition, reliability, or efficiency, and may impose burdensome administrative costs ultimately borne by consumers.

ENA submission to the Commerce Commission about the draft decisions on the default price-quality paths (DPP) for electricity distribution businesses. The submission discusses the balance between consumer price impacts and necessary investments for maintaining safe and cost-effective electricity services, with a particular focus on revenue smoothing to mitigate price shocks.

ENA submission to the Ministry of Business, Innovation & Employment about the phase-out of Low Fixed Charge (LFC) Regulations. The submission argues for the continuation of the phase-out, citing its significance for more efficient distribution pricing and the development of innovative retail pricing enabled by electricity distribution businesses (EDBs).

ENA submission to the Electricity Authority about the proposed changes in the Code amendment omnibus three. The submission supports updating maximum distributed generation application fees and recommends adopting a mechanism to adjust these fees annually. It also suggests aligning Electricity Distribution Business and Transpower application fees and advocates for the inclusion of transition provisions for new data reporting in the registry.

ENA submission to the Electricity Authority about improving retail market monitoring. It advocates for a comprehensive approach that will address disjointed monitoring and emphasises understanding consumer preferences and market conditions.

ENA submission to the Electricity Authority about the targeted reform of distribution pricing to facilitate New Zealand's transition to a low-emission economy. The submission emphasizes the need for the Authority to provide clear guidance to Electricity Distribution Businesses (EDBs) on efficient pricing methods to benefit consumers, while expressing concerns over potential regulatory interventions that might delay pricing reforms.

ENA submission to the Electricity Authority regarding Benchmark agreement and SRAM related Code changes. The submission supports the recovery of SRAM implementation costs by Transpower, amendments to the benchmark agreement, and an expanded pass-through option for settlement rebates, arguing that these measures ensure parity among EDBs, embedded networks, and customers.