Submissions

Submissions

We prepare and provide submissions to a number of regulatory, government department and industry bodies on issues affecting the electricity and gas industries. You can find those submissions here.

2026

October

Ministry for Cities, Environment, Regions and Transport - Illustrative National Policy Direction
Electricity Authority - Plug-in generation and Code Part 6 updates

September

Ministry of Business Innovation and Employment – options to improve the efficiency of electricity distribution businesses (Powerco submission)
Ministry of Business Innovation and Employment – options to improve the efficiency of electricity distribution businesses (joint submission of Aurora, Orion, Powerco, Unison, Vector, Wellington Electricity)
External Reporting Board – Climate reporting roadmap
Energy Efficiency and Conservation Authority - requirements for EV chargers

 

August

Commerce Commission - Orion Customised Price Path issues paper
Electricity Authority - Further connection pricing reform
Commerce Commission - draft guidance resilience principles in decision-making
Electricity Authority - Common quality information sharing

July

Gas Industry Company - Downstream reconciliation and switching rules
Electricity Authority - DSO roadmap
Transpower - System operator strategy Phase 2
Electricity Authority - Amendments to transmission pricing methodology
Electricity Authority - Market operation service provider roadmap
Ministry for the Environment - Reducing emissions from organic waste

June

Electricity Authority - BESS and hybrid BESS common quality and wholesale market arrangements
Electricity Authority - Options to address harmonics
Electricity Authority - Improving information on network capacity
Transpower - Tararua major capex proposal
Electricity Authority - Code review programme no.7

May

Electricity Authority - Distributed generation pricing principles


April

Commerce Commission - Hybrid mechanism for gas distribution
Department of Prime Minister and Cabinet - Critical infrastructure cyber security
Commerce Commission - Common cost of capital
Electricity Authority - Incorporating connected asset commissions, testing and information standards into the code

March

Transpower - Te Kanapu 3
Commerce Commission, Electricity Authority and EECA - Accelerating non-network solutions
Energy Efficiency and Conservation Authority – Work programme and levy FY27

February

Transpower – System Operator Strategy
Transpower - Waikato upper North Island upgrades
Electricity Authority - Multiple trading relationships supplementary consultation
Parliament Select Committee - Planning bill and natural environment bill
Parliament Select Committee - Emergency Management Bill
Gas Industry Co - FY27 work programme and levy
Commerce Commission - Gas DPP4 draft decision - cross submission
Energy Competition Task Force - 2026 Work programme
Electricity Authority - Connection upfront charges and distributor obligations

January

Minister of Energy - letter about EDB collaboration and efficiency
Commerce Commission - Gas DPP4 draft decision

Electricity Authority - Part C minor code amendment, electricity connections

Electricity Authority - Defining small businesses for distributed generation rebates

Electricity Authority - Half hour data for reconciliation

Electricity Authority - Wholesale market for battery energy storage systems

Electricity Authority - Distributed generation export limits

Transpower - Te Kanapu consultation 2 - Potential scenarios

Electricity Authority - Network visibility

Transpower - Connected asset commissioning, testing and information standard

Commerce Commission - Open letter on electricity DPP4

Electricity Authority - Connections stage one code amendment

Commerce Commission - Aurora CPP to DPP transition

Electricity Authority - Emergency reserve scheme

Ministry of Business Innovation and Employment - Electricity consumer data right

Electricity Authority - Future system operation

Electricity Authority - Common quality code amendment

Ministry of Housing and Urban Development - Package 4 - Going for housing growth

Infrastructure Commission - draft national infrastructure plan

Electricity Authority - Regulatory roadmap for battery energy storage systems

Ministry for the Environment - Package 3: Freshwater

Ministry for the Environment - Package 2: Primary Sector

Ministry for the Environment - Package 1: Infrastructure and Development

Electricity Authority - multiple retailing and switching

Commerce Commission - Gas DPP4 issues paper

Electricity Authority - Digitalisation

Electricity Authority - rewarding industrial flexibility

Gas Industry Company - Gas information exchange protocols

Electricity Authority - Frequency related Code amendment

Electricity Authority - Decentralisation green paper

Ministry for the Environment - waste legislation amendments

National Emergency Management Agency - Strengthening NZ's emergency management legislation

Commerce Commission - Open letter on fibre input methodologies

Commerce Commission - Transpower Western Bay of Plenty major capex project proposal

Gas Industry Company - guidelines for regional critical contingencies

Electricity Authority - cross submission distributed generation pricing principles

Electricity Authority - cross submission competition taskforce 2a distributor peak export rate

Electricity Authority - Distributed generation pricing principles

Electricity Authority - Competition taskforce 2b and 2c time-varying retail pricing

Electricity Authority - Competition taskforce 2a distributor peak export rate

Commerce Commission - Water services information disclosure

Commerce Commission - Gas DPP4 open letter

Electricity Authority - Connection pricing and process - cross submission

Ministry of Business Innovation and Employment - Commerce Act targeted review

Parliament Select Committee - Resource Management Amendment Bill

 

Electricity Authority - Distribution connection pricing

Electricity Authority - Network connections project stage 1

Ministry of Business Innovation and Employment – extension of the LV voltage range

Te Waihanga Infrastructure Commission - National Infrastructure Plan - testing our thinking

Electricity Authority - Forecasting provisions for intermittent generators

Electricity Authority - Common quality Part 8 code proposals and information requirements

Electricity Authority - First steps in improving outage coordination

Ministry of Business Innovation and Employment - Exploring a consumer data right for electricity

Parliament Select Committee - Crown minerals bill

Electricity Authority - Code review programme no.6

Parliament Select Committee - Regulatory systems bill

Parliament Select Committee - Customer and product data bill

Electricity Authority - Addressing more frequency variability

Ministry for the Environment - Emissions reduction plan 2

Electricity Authority - Proposed changes to the default distributor agreement

Ministry of Business Innovation and Employment - Making it easier to build granny flats

Commerce Commission - DPP4 draft decision - cross-submission

Ministry of Business Innovation and Employment - Regime for carbon capture use and storage

Commerce Commission - DPP4 draft decision

Commerce Commission - DPP4 opex step-change information

Parliament Select Committee - Resource Management (freshwater and other matters) amendment bill

Ministry for the Environment - Emissions trading scheme settings

Parliament Select Committee - Privacy amendment bill

Parliament Select Committee - Climate adaptation inquiry

Electricity Authority - Code omnibus three

Climate Change Commission - Emissions budget 4 and 2050 target review

Parliament Select Committee - Fast track approvals bill

Electricity Authority - Future operation of New Zealands power system

Commerce Commission - DPP4 financeability

Gas Industry Company - Reconciliation Rules

Electricity Authority - Omnibus two consultations

 

Commerce Commission - DPP4 issues paper

Electricity Authority - Proposed changes to default distributor agreement

Ministry for the Environment - Proposed NPS for Natural Hazard decision making

Ministry of Business Innovation and Employment - Gas Transition plan issues paper

Parliament Select Committee - Emergency Management Bill

Ministry of Business Innovation and Employment - Market measures for the energy transition

Parliament Select Committee - Inquiry into climate adaptation

Ministry for the Environment – Review of the New Zealand Emissions Trading Scheme  

Department of Prime Minister and Cabinet – Strengthening the resilience of the critical infrastructure system  

Electricity Authority – Ensuring an orderly thermal transition 

Commerce Commission – Draft Input Methodologies determination

Commerce Commission – DPP4 process paper

Climate Change Commission – advice on the 2026-2030 Emissions Reduction Plan

Ministry of Business, Innovation and Employment - Strengthening national direction on renewable electricity generation and electricity transmission

Ministry of Transport – draft Charging Our Future strategy 

Ministry of Business, Innovation and Employment – Proposed strategies to address energy hardship

Ministry of Business, Innovation and Employment – Enabling offshore renewable energy 

Electricity Authority – EDB regulatory settings

Government – Water Services Legislation Bill

Government – Natural and Built Environment Bill

Commerce Commission - declining demand options

Commerce Commission - cost of capital