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Submissions to the Electricity Authority

The IEGA is making submissions to the Authority on Code change proposals that impact distributed generation.  

The major issue we have addressed is proposed changes to the transmission pricing methodology (TPM) which is ongoing.  

The IEGA also made substantial submissions on the Authority's proposals to change the payment from distribution companies to distributed generation referred to as ACOT.

Reform of distribution pricing as well as consultation relating to emerging technologies and real time pricing proposals are also topics the IEGA is following.

Submissions are listed below in chronological order.

Implementing Transmission Pricing Methodology Guidelines

In June 2020 the Electricity Authority finalised and published the Transmission Pricing Methodology Guidelines. Transpower is now working to develop the detailed transmission pricing methodology that is consistent with the Guidelines. New transmission charges based on the 2020 Guidelines are expected to come into force on 1 April 2023.

Under the new Guidelines Regional Coincident Peak Demand is no longer relevant and will not be measured after September 2021.

IEGA submissions to Transpower on transmission pricing methodology

The IEGA has made the following submissions to Transpower as they work to develop a methodology consistent with the Guidelines. Information about Transpower’s TPM Development project is available here.

TPM Development - TPM Options, 14 December 2020

TPM Development - transitional congestion charge, 20 October 2020

TPM Development - connection charge, 15 September 2020

2019 Transmission Pricing Proposals

EA Board response to IEGA letter, 10 June 2020

Letter to EA Board on lack of consultation peak transmission charge, 28 May 2020

IEGA submission - 2019 TPM proposal, supplementary consultation, 3 March 2020

IEGA Cross-submission, 31 October 2019

King Country Energy cross submission 31 October 2019

IEGA submission - TPM proposal 1 October 2019

Pioneer Energy submission on 2019 TPM Proposal 1 October 2019

Distribution pricing

IEGA submission - more efficient distribution pricing, 19 February 2019

IEGA submission to Electricity Networks Association on new pricing options for distributors 20 December 2016

Real-time pricing proposals

IEGA submission - Real-time pricing proposals, 30 April 2019

IEGA submission on real-time pricing proposals, 10 October 2017

Emerging technologies project by Commerce Commission and Electricity Authority

IEGA submission - feedback on workshop on emerging contestable services, 25 June 2019

IEGA submission, 12 April 2019

Submissions on DG eligible for ACOT analysis for 4 transmission regions

Kawatiri Energy submission UNI and USI, 9 October 2018

Inchbonnie Hydro submission UNI and USI, 9 October 2019

IEGA submission on Upper South Island eligible DG - supplementary information, January 2019

Report by EnergyLink on impact on spot price of cessation of load control in USI

IEGA submission to EA on Upper South Island and Upper North Island eligible DG, 9 October 2018

IEGA submission to EA on Lower South Island eligible DG, 30 January 2018

NZ Energy submission on Lower South Island eligible DG, 30 January 2018

Cross Submissions on Transmission Pricing Proposals

IEGA cross submission, 24 March 2017

Pioneer Energy cross submission, 24 March 2017

Submissions on Transmission Pricing Proposals

IEGA submission on TPM Second issues paper Supplementary consultation, 24 February 2017

NZ Energy Ltd submission on TPM Second issues paper Supplementary consultation, 24 February 2017

Pioneer submission on TPM Second issues paper Supplementary consultation, 24 February 2017

Pioneer submission - July 2016: Cover letter, submission, analysis of CBA

NZ Energy Ltd submission on TPM Second issues paper, July 2016

IEGA reports on DGPP proposals

IEGA Summary of Submissions - October 2016

IEGA DGPP Proposals Q & A - September 2016

Judicial Review

AFFIDAVIT: Final affidavit by Grant Smith, Pioneer Energy, 29 August 2016

Submissions by IEGA and members

The IEGA submission and submissions by IEGA Members are below:

IEGA Submission and PWC Report

A D Harwood Submission

Anonymous Submission

Eastland Generation Submission

Electra Generation Submission

Energy3 Submission

HydroWorks Submission

Inchbonnie Hydro Submission

Kawatiri Energy Submission

King Country Energy Submission

NZ Energy Submission

Nova Energy Submission

Omanawa Falls Hydro Submission

Onekaka Energy Submission

Pioneer Energy Submission

Pupu Hydro Society Inc. Submission

The Electricity Authority received 54 submissions - find all of the submitted documents here: Submissions to EA

Previous submissions by the IEGA on the Electricity Authority’s TPM and ACOT proposals are listed below.

June 2016

IEGA sought an extension to the consultation period for the Review of the distributed generation pricing principles:

https://www.ea.govt.nz/dmsdocument/20882

The EA declined this request:

https://www.ea.govt.nz/dmsdocument/20883

May 2016

EA presentation to an IEGA meeting 26 May 2016: DGPP and TPM second issues papers - IEGA meeting 26 May 2016

August 2015 – TPM Options Paper

IEGA submission:  https://www.ea.govt.nz/dmsdocument/19777 and   https://www.ea.govt.nz/dmsdocument/19775

October 2014 - TPM Problem Definition: Interconnection and HVDC

IEGA submission:  https://www.ea.govt.nz/dmsdocument/18697

August 2014

EA presentation to an IEGA meeting: https://www.ea.govt.nz/dmsdocument/18426

January 2014 – TPM Review – ACOT Working Paper

IEGA submission:  https://www.ea.govt.nz/dmsdocument/17090  and https://www.ea.govt.nz/dmsdocument/17089