Submissions

ENA submission to the Inland Revenue about the consultation on taxation of amounts paid to households selling excess electricity. The submission focuses on concerns regarding the potential financial and administrative burdens of the proposed tax changes, emphasising the evolving nature of flexibility markets, and highlights the importance of considering equity and policy intent to avoid unintended consequences.

ENA submission to the National Emergency Management Agency about improving New Zealand’s emergency management legislation to enhance infrastructure resilience and response coordination. The submission supports legislative reforms to clarify roles within civil defense groups, advocates for consistent engagement with critical infrastructure providers, and underscores the importance of practical resilience planning and data sharing.

ENA submission to the Commerce Commission about the review of the fibre input methodologies. The submission discusses the current methodologies for the weighted average cost of capital (WACC) and suggests the inclusion of alternative methodologies to improve outcomes for consumers.

ENA cross-submission to the Electricity Authority about the Distributed Generation Pricing Principles (DGPPs). The submission supports a comprehensive review of DGPPs to clarify areas of disagreement and address perceived inconsistencies in the regulatory framework.

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 Finance and Expenditure Committee about concerns with the Local Government (Water Services) Bill. The submission highlights issues with clauses that allow third parties to modify or remove electricity infrastructure, which ENA believes could pose security, cost, and safety risks, and suggests amendments to align with existing laws.

ENA submission to the Environment Select Committee about the Resource Management (Consenting and Other System Changes) Amendment Bill. The submission discusses the need for an efficient consenting scheme to support infrastructure development necessary for New Zealand's electrification and climate change targets, advocating for specific amendments to ensure infrastructure resilience and to streamline administrative processes.

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 Ministry for Regulation about the Proposed Regulatory Standards Bill discussion document. The submission supports the intent of improving regulatory quality and urges for a regulatory framework that balances cost, efficiency, and sustainability while meeting New Zealand’s decarbonisation goals.

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 proposed regulatory changes in the distribution sector, focusing on load connection obligations and standardsation of connection processes. The submission expresses concerns about reintroducing obligations that were previously removed by legislation and highlights potential issues with the practicality of proposed timelines and regulatory requirements.

ENA submission to the Infrastructure Commission Te Waihanga about the development of a long-term National Infrastructure Plan that addresses New Zealand's infrastructure challenges over the next 30 years. The submission emphasises the need for collaboration among infrastructure providers to electrify the economy, tackle climate goals, improve infrastructure resilience, and manage risks associated with extreme weather events and other future uncertainties.