Our submissions

When the Government or electricity industry regulators issue something for consultation — such as an amendment to a Bill, or a pricing review — we will comment on it, on behalf of residential and small business electricity consumers.

We do this in a number of ways. We may:

• make a formal submission to Parliament
• attend a Select Committee hearing
• meet directly with industry regulators and companies.

You’ll find details of all our submissions here.

2022 submissions

Promoting competition in the wholesale electricity market in the transition toward 100% renewable electricity

The Council made a number of recommendations in its December 2022 submission, including that the Electricity Authority:

1. specifically ensures equity and fairness for small consumers be applied to its interpretation of its expanded objective, alongside the existing 'limbs' of competition, reliable supply and efficient operation.
2. ensures that residential and small business electricity bills have the best information available to incentivise and enable demand responses.
3. recognises the limited ability of residential and small business consumers to respond to price and places them at the centre of its decisions about price, reliability, sustainability, and the structure of the electricity market.
4. provides leadership in connecting management of electricity supply to other government policy objectives (and responsible agencies) where there are intended and unintended impacts on health, poverty alleviation and climate change.
5. uses additional metrics other than economic in assessing appropriate regulatory settings.
   in relation to the transition to renewable energy
6. investigates and reports on whether the current wholesale market model is fit for purpose to meet consumers' needs and delivers a fairly priced and reliable electricity supply, and considers incentives to ensure sufficient new renewable generation can enter the wholesale electricity market.
7. investigates and reports on alternative models, including, as a starting point:
   1. treating renewables and non-renewables separately in the wholesale market
   2. developing a flexible and equal access market as suggested by the Innovation and Participation Advisory Group in its advice to the Authority dated July 2021
8. Investigates and reports back on possible options to improve current settings that could be included in New Zealand's energy strategy.

Read the full submission below. 

Find out more about the consultation on the wholesale electricity market by visiting the Electricity Authority website.

Promoting competition in the wholesale electricity market in the transition toward 100% renewable electricity(external link)

Driving efficient solutions to promote consumer interests through winter 2023

The Council submitted the following recommendations to the Electricity Authority in December 2022:

1. longer consultation periods are needed to ensure meaningful participation in the Authority’s processes from consumers and smaller organisations.
2. options for winter 2023 should be assessed using these principles:
   1. Fairness to residential and small business consumers - electricity is an essential service and reliability of supply in winter is crucial due to high dependence on electricity, particularly for heating for households.
   2. Small consumers should not bear the brunt of winter shortages: the electricity industry should have been better prepared for winter demand. Therefore, small consumers should not be expected to shoulder the consequences of the operational coordination problems evident in the current management of supply.
   3. Consumers should not be unfairly required to pay for the costs of market failure while generators are making large windfall profits. Instead, windfall profits of generators should be utilised to help get consumers through winter.
3. The Council supports options A, B, D and E, and strongly supports option H for further investigation. It also supports investigation of option K.
4. Whichever solutions are implemented, consumers should not be left to absorb additional costs.

Read the full submission below. 

Find out more about the consultation on the wholesale electricity market by visiting the Electricity Authority website.

Driving efficient solutions to promote consumer interests through Winter 2023(external link)

Inefficient Price Discrimination in very large electricity contracts

The Council made a submission to the Electricity Authority in October 2022. The Council:

1. supports the proposed amendments to the Code addressing the prospect of inefficient price discrimination.
2. suggests this proposal ensures the EA is meeting its expanded mandate to include small consumers in its assessments and not solely focusing on the wholesale pricing impact.
3. recommends that the EA reconsider investigating the over the counter (OTC) contracting between generator-retailers and independent retailers.
4. suggests amending Clause 13.269(1)(b) proposed Code wording

Read the full submission at the bottom of the page. 

Find out more about this proposed Code amendment by visiting the Electricity Authority website. 

Inefficient Price Discrimination in very large electricity contracts(external link)

Commerce Commission 2023 input methodologies review

The Council made a submission to the Commerce Commission in July 2022, recommending:

1. The introduction of a cost benefit analysis that takes a whole of life approach to network investment, allowing for the long-term benefit of a well-planned and managed electricity supply system, including:
   1. investment to meet decarbonisation as technology and consumer energy demands change;
   2. network resilience with timely access to data particularly on low voltage networks; and
   3. allowing capacity for growth.
2. The Electricity Authority control the average revenue allocation requirements.
3. More transparency requirements on constrained sections of networks be included, including:
   1. under or over voltage;
   2. the number of premises that could not inject electricity into the network, this includes publication of "maximum export power' for domestic consumers on
      section of the network;
   3. the number of applications to connect distributed generation that were refused: and 
   4. the sections of network that exceeded 75% of its rated capacity.
4. More requirements that allow for technological advancements and flexibility that ensures networks are keeping pace with change, and includes:
   1. meeting our climate change requirements;
   2. allowing more flexibility for 'embedded networks'; and
   3. meeting future demand.

Read the full submission at the bottom of the page.

Find out more about input methodologies and the 2023 review by visiting the Commerce Commission website.

2023 input methodologies review(external link)  

Transmission charge pass-through 

The Council made a submission to the Electricity Authority in September 2022 recommending:

1. Distributors should ensure that retailers have information to respond efficiently to customer queries if pricing plan rates change due to changes in transmission charges.
2. All industry bodies need to agree upon consistent messaging to small consumers about the nature of any changes and why they are occurring.
3. A mix of fixed and variable charges should be introduced.
4. The guidelines should include recommendations on spreading adjustments over an implementation period so that no consumer's overall retail electricity cost exceeds a 5% increase in any one year.
5. Allocation of pass-through of costs should be transparent and consistent with the distributor's pricing methodology required by the Commerce Commission.

Read the full submission at the bottom of the page. 

Find out more about distribution pricing on the Electricity Authority website.

Distribution pricing (external link)

2021 submissions

Electricity Industry Amendment Bill

The Council made a submission to the Economic Development, Science and Innovation Committee in November 2021.

Our recommendations are:

1. Establishing a consumer advocacy agency to deliver the work of the Council.
2. Ensuring the independence of the consumer advocacy agency by requiring it in governing legislation.
3. Providing regulation-making powers to recover the costs associated with the consumer advocacy agency by way of an industry levy.
4. Removing any ambiguity between the Council and the Agency to clarify that the Council will deliver the work of the Agency.
5. Amending the small business consumer definition to be consistent with the standardised definition of SMEs of less than 20 employees.
6. Clarifying the roles and responsibilities of the regulators.
7. Expanding the Electricity Authority's consumer protection objective to protect the interests of residential and small business consumers in relation to the supply of electricity.
8. Ensuring the Electricity Authority can develop proportionate and targeted rules to address competition-related issues in contestable markets.

Read the full submission below. 

 You can read more about the Electricity Industry Amendment Bill on Parliament's website.

Electricity Industry Amendment Bill(external link)