[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-1-en-105":3,"doc-seo-281873-105":53,"doc-detail-281873-en":127},{"code":4,"msg":5,"data":6},0,"success",[7,14,19,24,29,34,39,44,49],{"id":8,"doc_module":9,"doc_module_name":10,"category_name":11,"show_sort_weight":12,"slug":13},11,1,"Template","Presentations",90,"presentations",{"id":15,"doc_module":9,"doc_module_name":10,"category_name":16,"show_sort_weight":17,"slug":18},12,"Resumes",80,"resumes",{"id":20,"doc_module":9,"doc_module_name":10,"category_name":21,"show_sort_weight":22,"slug":23},14,"Invoices",70,"invoices",{"id":25,"doc_module":9,"doc_module_name":10,"category_name":26,"show_sort_weight":27,"slug":28},15,"Posters",60,"posters",{"id":30,"doc_module":9,"doc_module_name":10,"category_name":31,"show_sort_weight":32,"slug":33},16,"Social Media",50,"social-media",{"id":35,"doc_module":9,"doc_module_name":10,"category_name":36,"show_sort_weight":37,"slug":38},17,"Forms",40,"forms",{"id":40,"doc_module":9,"doc_module_name":10,"category_name":41,"show_sort_weight":42,"slug":43},18,"Letters",30,"letters",{"id":45,"doc_module":9,"doc_module_name":10,"category_name":46,"show_sort_weight":47,"slug":48},21,"Paper Templates",5,"papers-templates",{"id":50,"doc_module":9,"doc_module_name":10,"category_name":51,"show_sort_weight":4,"slug":52},158,"General","general-158",{"code":4,"msg":54,"data":55},"ok",{"site_id":56,"language":57,"slug":58,"title":59,"keywords":60,"description":61,"schema_data":62,"social_meta":120,"head_meta":122,"extra_data":124,"updated_unix":126},105,"en","ena-submission-on-proposed-changes-to-the-default-distribution-agreement-template-submission-to-the-electricity-authority","ENA submission on proposed changes to the default distribution agreement template - Submission to the Electricity Authority","","Submission by Electricity Networks Aotearoa (ENA) to the Electricity Authority on proposed amendments to the default distribution agreement (DDA). The executive summary supports embedding the ENA/ERANZ data template in the Electricity Industry Participation Code and welcomes its codification, while challenging aspects of the proposal that ENA views as exceeding the Authority’s jurisdiction. ENA argues that removing recorded terms and mandating refunds and risk apportionment changes overlook price-quality trade-offs, outage service continuity, and cost-benefit and consumer pass-through considerations.",{"@graph":63,"@context":119},[64,80,102],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/ena-submission-on-proposed-changes-to-the-default-distribution-agreement-template-submission-to-the-electricity-authority/281873/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/ena-submission-on-proposed-changes-to-the-default-distribution-agreement-template-submission-to-the-electricity-authority/281873.png","ImageObject",442,249,{"name":88,"@type":89},"Elsa","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-19","2026-09-16",true,{"@type":98,"interactionType":99,"userInteractionCount":101},"InteractionCounter",{"@type":100},"ViewAction",10,{"@type":103,"mainEntity":104},"FAQPage",[105,111,115],{"name":106,"@type":107,"acceptedAnswer":108},"What is ENA’s position on codifying the ENA/ERANZ data template?","Question",{"text":109,"@type":110},"ENA welcomes the Authority’s proposal to codify the ENA/ERANZ data template and embed it in the Code, as it reduces the need for case-by-case negotiation between EDBs and Traders for routine data access.","Answer",{"name":112,"@type":107,"acceptedAnswer":113},"Why does ENA believe two proposed Core terms exceed the Authority’s jurisdiction?",{"text":114,"@type":110},"ENA argues the proposed Core terms fall outside the Electricity Authority’s jurisdiction and interfere with the Commerce Commission’s powers related to setting maximum prices and revenues, which the Electricity Industry Act and the Commerce Act framework reserve to the Commission.",{"name":116,"@type":107,"acceptedAnswer":117},"What concerns does ENA raise about the proposed refund of charges and the risk apportionment changes?",{"text":118,"@type":110},"ENA states the refund mechanism goes beyond jurisdiction and fails to account for ongoing line and transmission services during outages, and it also does not pass the cost-benefit and consumer pass-through considerations. ENA further contends proposed changes to clause 24.5 would prevent EDBs from clearly excluding certain liability categories, disturbing the balance of risk apportionment.","https://schema.org",{"og:url":78,"og:type":121,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":123,"canonical":78},"index,follow",{"doc_id":125,"site_id":56},281873,1790688321,{"code":4,"msg":5,"data":128},{"doc_id":125,"user_id":129,"nickname":88,"user_avatar":130,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":131,"file_id":132,"file_url":133,"file_type":134,"file_size":135,"view_count":101,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":15,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":79},137455077381,"https://ap-avatar.wpscdn.com/davatar_994ba38a5ba835b3df7d355c54d3ed8d","ENA submission on proposed changes to the default distribution agreement template  \nSubmission to the Electricity Authority  \nDATE  \n14 November 2023  \nNAME OF SUBMITTER  \nElectricity Networks Aotearoa  \nINDUSTRY/AREA OF INTEREST  \nUtilities/infrastructure  \nCONTACT  \nKeith Hutchison  \nADDRESS  \nLevel 5, Legal House  \n101 Lambton Quay  \nWellington 6011  \nTELEPHONE  \n+64 4 471 1335  \nEMAIL  \n[Keith@electricity.org.nz](Keith@electricity.org.nz)  \nContents  \n1 Introduction 3  \n\n| 2 | Executive Summary | 3 |\n| --- | --- | --- |\n| 3 | Codification of the ENA/ERANZ data template is welcomed | 4 |\n| 4 | Two clauses exceed the Authority's jurisdiction | 4 |\n| 5 | Drafting amendments and new Core terms | 5 |\n| 6 | Proposed changes to Part 12A of the Code | 8 |\n\n7 The cost of re-issuing current DDAs is not captured in the CBA 8 Appendix A-ENA Membership 10 Appendix B-Consultation Paper Questions 11  \n1 Introduction  \nElectricity Networks Aotearoa (ENA) appreciates the opportunity to make a submission to the Electricity Authority (Authority) on its proposed changes to the default distribution agreement (DDA) .  \nENA represents the 27 electricity distribution businesses (EDBs) in New Zealand (see Appendix A) which provide local and regional electricity networks. EDBs employ 10,000 people and deliver energy to more than two million homes and businesses.  \n2 Executive Summary  \nENA welcomes the Authority’s recognition of the benefits of the ENA/ERANZ data template being embedded in the Electricity Industry Participation Code (the Code) . ENA continues to support the codification and use of the ENA/ERANZ data template.  \nENA appreciates that the Authority's proposal to remove recorded terms from the DDA is a direct response to the findings of the 2022 investigator’s examination of several EDBs recorded terms1 and subsequent changes to the Electricity Industry Act 2010 (EIA) . ENA believes the Authority has erred in its reaction to these events and views the arbitrary use of Core terms to replace the recorded terms as an overreaction.  \nWhile the amended EIA provides the Authority with the ability to regulate quality, the Authority's proposed amendments to the DDA do not consider the price-quality trade-offs that are implicit in the regulation of service quality.  \nENA’s view is that two of the proposed Core terms are not within the Authority’s jurisdiction and directly interfere with the Commerce Commission's (Commission’s) powers in relation to setting maximum prices/revenues. The EIA explicitly prohibits the Authority using the Code to “purport to do or regulate anything that the Commerce Commission is authorised or required to do or regulate under Part 3 or 4 of the Commerce Act 1986” which includes determining maximum prices2 or revenues.  \nThe Authority's proposed use of Core terms to mandate the refund of charges not only goes beyond its jurisdiction but fails to recognise that the provision of line services does not stop during an outage, nor do transmission services and the associated transmission charges. Restoration of supply is a core service, which lines charges funds; accordingly, proposing a mechanism to reduce funding to a core service mechanistically is illogical. Further, this change fails the cost-benefit test and the absence of a similar obligation on Traders means any refund would not necessarily be passed to consumers.  \nThe Authority’s proposed clause 24.5 fails to strike an appropriate balance for the apportionment of risk. Under the proposed changes to this clause EDBs may no longer be able to expressly exclude liability for:  \n• originating in embedded networks and embedded generators;  \n• origination in Transpower’s network;  \n• due to extreme weather events (only ‘natural disasters’ are referenced and would be interpreted very narrowly);  \n• due to vegetation and animals; or  \n• Trader’s negligence or breach of Good Electricity Industry Practice.  \n1 Electricity Authority, 2022, Notice of the Authority’s decision u","cbCaifbfRZcocmhd","https://ap.wps.com/l/cbCaifbfRZcocmhd","pdf",446461,"English","# 1 Introduction\n# 2 Executive Summary\n## 3 Codification of the ENA/ERANZ data template is welcomed\n## 4 Two clauses exceed the Authority's jurisdiction\n## 5 Drafting amendments and new Core terms\n## 6 Proposed changes to Part 12A of the Code\n## 7 The cost of re-issuing current DDAs is not captured in the CBA\n# Appendix A-ENA Membership\n# Appendix B-Consultation Paper Questions","[{\"question\":\"What is ENA’s position on codifying the ENA/ERANZ data template?\",\"answer\":\"ENA welcomes the Authority’s proposal to codify the ENA/ERANZ data template and embed it in the Code, as it reduces the need for case-by-case negotiation between EDBs and Traders for routine data access.\"},{\"question\":\"Why does ENA believe two proposed Core terms exceed the Authority’s jurisdiction?\",\"answer\":\"ENA argues the proposed Core terms fall outside the Electricity Authority’s jurisdiction and interfere with the Commerce Commission’s powers related to setting maximum prices and revenues, which the Electricity Industry Act and the Commerce Act framework reserve to the Commission.\"},{\"question\":\"What concerns does ENA raise about the proposed refund of charges and the risk apportionment changes?\",\"answer\":\"ENA states the refund mechanism goes beyond jurisdiction and fails to account for ongoing line and transmission services during outages, and it also does not pass the cost-benefit and consumer pass-through considerations. ENA further contends proposed changes to clause 24.5 would prevent EDBs from clearly excluding certain liability categories, disturbing the balance of risk apportionment.\"}]","ENA submission on proposed changes to the default distribution agreement template - Submission to the Electricity Authority | PDF",1789568734]