Mar 21, 2025
Fight for a fair system: Rewiring Aotearoa's submission guide for the Energy Competition Task Force consultation

This consultation is a key input into unlocking some benefits that will speed up the adoption of solar and batteries, increase system sizes, and help create the lowest possible cost energy system for Aotearoa New Zealand. We believe that many of the proposals are positive steps and have recognised the technological and economic shifts that are happening in energy, but there is still some bias against investments made by homes and farms towards investments made by networks and energy companies. Whether you've got five minutes or a few hours, your submission can have a real impact on the final decisions and ensure the playing field is made level. Here's how to make your voice heard.

Submissions are due 5pm Wednesday 26 March 2025

What’s the deal?

The Energy Competition Task Force (the Task Force), jointly established by the Electricity Authority Te Mana Hiko and the Commerce Commission Te Komihana Tauhokohoko, has a programme of work underway taking action to strengthen the performance of the electricity market in the short to medium-term, for the benefit of all consumers.

We at Rewiring Aotearoa are excited at the potential for real action that benefits consumers, but this outcome is not assured! 

The Task Force is currently consulting on a range of proposals that seek to empower electricity consumers to take better control of their own energy bills. What the Task Force decides to do will play a critical role in the next five to ten years in driving household-level decisions on energy production, use and storage. 

There are significant issues with some of the Task Force’s “proposed solutions”, and we would appreciate your help in convincing the Task Force to be more ambitious.

They have three sets of proposals:

  • 2A:  Requiring distributors (entities who own and operate local poles and wires to distribute electricity) to pay a rebate (payment to consumers) when consumers supply electricity at peak times.
  • 2B: Requiring bigger retailers to offer and promote time of use price plans available to mass-market consumers.
  • 2C: Requiring bigger retailers to offer variable buy-back rates to reflect the higher value of electricity supplied at peak times.

There is a helpful and understandable “Overview for consumers” of proposals on the Electricity Authority’s website. 

This guide explains Rewiring Aotearoa’s high level response to the Task Force’s proposals and helps everyday Kiwis, innovators and other groups have their say, with a focus on getting the best possible outcome for all consumers.

  • Need more info? Read the quick guide.
  • Share this page or this doc on socials and get more friends pushing for household electrification: the more the merrier. 
  • Need some help or want to chat through anything? Email us at hello@rewiring.nz and we’ll see what we can do. We are happy to talk to you about any of the details here. We spend a lot of time thinking about how to make the energy system fair, efficient, and low cost for New Zealanders into the future.
  • Keep up with the play: Follow Rewiring Aotearoa on LinkedIn, Instagram, Twitter, Facebook for updates or subscribe to Rewiring Aotearoa’s newsletter. You can also visit Rewiring Aotearoa’s website, or download our ‘Electric Homes’ and ‘Electric Farms’ papers.

We are working on our own submission that will be going deep into the weeds of energy geekdom, especially on initiative 2A. We will release this on our website as soon as it is done. The more submissions that back up the general thrust of our submission and the more personal stories that are received, the more likely we all are to have a positive impact.

The consultation also provides an opportunity to highlight other roadblocks you have experienced that are relevant to the consultation’s aim of better empowering consumers to manage costs, consumption and investment decisions. The Electricity Authority is also working to help innovators who are coming up with new ways to harness technology and developing solutions to some of the challenges in the system. Give them an email on innovate@ea.govt.nz and check out their Power Innovation Pathway to learn more.

Why does this consultation matter?

It is in the interest of all consumers that more households, farms and businesses install solar and batteries and that they maximise the size of those installs. The more solar generation, the more water can be kept in our hydro lakes (and in turn less gas and coal needs to be burned); the more batteries, the less we will need to invest in poles and wires to deal with our peaks (currently forecast to be tens of billions a decade and the main component of bill increases in coming years); the more EVs charged by solar, the less fossil fuels there will be in the wider energy system (and more batteries on wheels that could power our homes and feed into the grid). 

A lot of a little is a lot and Rewiring Aotearoa's research suggests that if a 9kW solar system (or approximately 20 panels) was added to 80% of New Zealand’s two million homes the combined generation would add 40% more electricity than today. It would also massively cut the energy bills of all those homes.

If the approximately 50,000 farms in New Zealand did as we did and added rooftop and groundmount solar, that would be another 60%. The Government’s aim is to double the supply of renewable electricity and it could reach that goal largely by focusing on existing rooftops and unproductive land. 

Like highways, we build our electricity system to handle the peaks, but batteries - either on the wall or, in the future, in your driveway - basically remove your home from peak, and exporting removes your neighbours from peak. 

Just 120,000 homes (or around five percent of households in New Zealand) with a medium-sized battery could potentially reduce the peak load as much as New Zealand’s largest hydro power station, Manapouri, but only for a few hours when we really need it. These batteries would have enough energy to cover our winter spikes in demand and recharge during off peak times. More batteries in homes and on farms can collectively shave billions of dollars off spending on poles and wires over the coming decades; billions that all consumers would need to fund.

All the electric vehicles in the country will eventually be one of New Zealand’s biggest batteries. Vehicle-to-load or vehicle-to-grid, which requires bi-directional charging, recently got through the first major regulatory hurdle in Australia and many modern EVs include this feature, so this future may not be too far away. 

There are still barriers in the way and some of the changes proposed aim to address them. This consultation is a key input into unlocking some benefits that will speed up adoption and help create the lowest possible cost energy system for Aotearoa New Zealand. We believe that many of the proposals are positive steps and have recognised the technological and economic shifts that are happening in energy, but there is still some bias against investments made by homes and farms towards investments made by networks and energy companies. Your submission can have a real impact on the final decisions and ensure the playing field is made level. 

We know that these economic signals are important and the potential financial benefits customers can get by being part of the market do influence adoption rates and system size. 

How to have your say

⚡If you have 90 seconds

Copy and paste these bullets and email them to taskforce@ea.govt.nz with ‘Energy Competition Task Force initiatives 2A, 2B and 2C’ in the Subject Line by 5pm Wednesday 26 March 2025:

  • I agree with the aim of providing consumers with more options, and that flexible distributed generation can help drive down costs for everyone into the future. 
  • I do not support the proposed solution of principles-based rebates as the method to require distributors to pay a rebate when consumers supply electricity at peak times. (2A)
  • Instead, I support a requirement for distributors to be required to pay consumption-linked injection tariffs, and that these be perfectly symmetrical. This requirement should apply to all consumers, not just mass market consumers. (2A)
  • I support the addition of a new requirement for electricity retailers to pay a more fair price to consumers who sell power, but recommend that this should extend into dry years and other extended periods of constrained supply, and that all times it reflects the value of this electricity (not solely the additional value at peak times). (2C)

🐝 Got 5 minutes?

Send a quick email submission.

Copy the email template below into a Word document and fill in the blanks.

  1. Two options to send:
    1. Email the Word document as an attachment to taskforce@ea.govt.nz with ‘Energy Competition Task Force initiatives 2A, 2B and 2C’ in the Subject Line by 5pm Wednesday 26 March 2025.
    2. If you are unable to send your document electronically, email taskforce@ea.govt.nz or ring the Task Force on 04 460 8860 to discuss options.

Be aware all submissions by default will be published (though you are welcome to indicate what part of your submission shouldn’t be published and why), and that there is an opportunity for cross-submissions (commenting on other submitter’s points) by 5pm Wednesday 9 April 2025.

Share this guide with your friends and ask them to follow your lead. 

🐇If you have 15 minutes

Same instructions as above, but add the personal touch to the ideas in the email template. The more personalised you make your submission, the more effective it will be. Connecting it to personal stories of the difference these changes will make to you (or would have made when you were making decisions on solar and/or batteries) are most effective. Even if only partly formed thoughts, your reflections on the impact on actual decision-making are incredibly valuable.

What can you do? 

You do not need to answer every question the EA asks across the documents, and you don't need to read the dozens of pages (although of course you're welcome to!). What will be most valuable for the Energy Competition Taskforce is your own experience and thoughts. 

In particular, why do you think these changes are important? What have (or would) your household considerations be when installing a solar system and/or home batteries? Would those decisions be different if there were stronger economic signals to export energy or shift usage? And are there examples you can see of an unfair playing field or unnecessary red tape that increases costs for households, farms or businesses? 

For example, if you were expecting to get on average 2-3 times as much for a unit of power exported, would you seek/have sought to install a larger system because the payback period would have been reduced? If export limits were more than 5kw, would you install a bigger system? If you were able to access plans where power cost more at peak, but a lot less outside of peak, would you have bought a battery (or a larger battery)? Has new technology like solar, batteries and EVs or economic incentives like time of use plans changed your behaviour when it comes to energy use and export? Feel free to get specific. 

If you want to add some other examples of this technology in action and the impact these changes could have, here are two case studies you can pull from: one from a homeowner in Wellington and the other from Rewiring Aotearoa CEO Mike Casey. 

A three person household in Wellington installed 6.8Kw of solar panels, a 6kW inverter, and a Powerwall 2 13.5kWh battery just over a year ago. The dad is an energy nerd who very actively investigated retail offerings and went with the only option we are aware of that includes Time of Use pricing paired with buy-back rates that match the rolling wholesale price every 30 minutes. This plan includes many of the features we expect to become more common once the Task Force implements the changes of this consultation. 

By being on this plan rather than a more common plan, they received an average export price over 12 months of 25.42c (versus 8-17.5c from most retailers per the Powerswitch site) for the 2,700kWh they exported. This amounts to $686.34 instead of $216-472.50, an extra $213-470 off energy bills per year. Rewiring Aotearoa’s preferred action for initiative 2A would add (based on some assumptions) an additional $550 or so of savings a year. 

While all this may not sound huge, taken together over 30 years (and not factoring in very likely power price increases) it adds up to $23,000-$30,500 ($6,500-$14,000 from likely changes due to our recommended approach to 2C, and another $16,500 from 2A, which is plenty alone to replace the battery when needed). With a majority of this unlocked by batteries, getting these changes correct will have a big influence on what households decide to install. It provides a clear investment signal, which historically the industry has thought are important for large corporations, but seemingly not everyday New Zealanders, who deserve the same clear investment signals.

This isn't even the main benefit they get from their system, as they also benefit hugely from the cheap power they produce and consume themselves. And peace of mind of keeping the lights on in an outage. 

Forest Lodge Orchard near Cromwell produces over 80% of the electricity it needs to run its 21 electric machines via rooftop and ground mount solar. It stores a lot of that electricity in batteries, so while its electricity consumption has increased by over 900% compared to the previous farmer after electrifying all its machines, it doesn’t use any more electricity at peak times so hasn't required any upgrades to the poles and wires. 

As well as saving around $40,000 per year on diesel, it is paid to export during congestion times and can power roughly 25 neighbouring homes, making the farm an additional $20,000 per year - and making it a net positive for the energy system. It is only thanks to a unique arrangement that fairly rewards Forest Lodge Orchard for their contributions back into the grid that the Orchard has been incentivised to install the additional batteries. Every home, farm and business should have access to fairer rewards like these for their contributions.  

There is also nothing stopping EDBs and retailers from implementing most of these changes now. So feel free to send your submission to them as well. 

Bonus points: share that you’ve made a submission and why this topic matters to you on social media.

🐢If you have an entire weekend…

Get stuck into the 150 or so pages of the two main documents and answer the 31 specific questions posed! Feel free to share where you get to with us as it will likely help us finalise our submission!

Email template

My name is [NAME], and I’m a [age/job/gender/parental status/whatever you identify with] from [location]. I, like many others, am excited by the potential of better empowering consumers who are fundamentally reshaping our energy future. While these proposals are a step in the right direction, key changes will ensure individuals make decisions that lead to Aotearoa New Zealand building out the cheapest yet most resilient energy system possible.

[Feel free to add personal thoughts here about why this is important to you.]

I agree with the stated aim of providing consumers with more options, and that flexible distribution generation can help drive down costs for everyone into the future. 

I also agree with the high-level problems identified: 

  • A missing distribution price signal for injection
  • Current injection plans tend to offer fixed rates only
  • Low awareness of benefits of time-varying price plans.

I agree with the proposal to require large retailers to offer Time of Use plans as this empowers consumers to take better control of their impact on the electricity system and their own bills (2B). 

[If you have any personal experience with Time of Use plans changing your energy usage, please describe this as it will likely strengthen the rationale for this proposed requirement. ]

However, I do not agree that the Task Force’s proposed solutions for 2A and 2C will address the problems and achieve what is required.

I agree with the addition of a new rule to “make sure power companies pay people who sell power to the network” (2C) and but that to do this the rule needs to to be explicitly extended beyond just “peak times” and into:

  1. Dry years and other extended periods of extra constrained supply 
  2. For all times, reflect the contribution of this power contribution to general supply and the role the energy is playing to reduce need for new generation assets, rather than just on the market value at peak times.

I agree that retailers should be required to pass through benefits to consumers from distributors paying a rebate for supply at peak times.

I support the addition of a requirement in the Code for distributors to pay a rebate when consumers supply electricity at peak times (2A). While I strongly support the objective of the proposed amendment, I do not support the proposed solution of principles-based rebates

Principles-based rebates would likely provide too much flexibility, be difficult to monitor and enforce, and not achieve the desired result. The benefits of this proposed solution are unlikely to outweigh the costs. 

Instead, I support the alternative option of consumption-linked injection tariffs (with adequate safety valves to ensure too much power does not flow back in). This would fairly apply similar pricing to both consumption and injection during peak times. I support this being a perfectly symmetrical export tariff, and not differential as suggested. This would also strongly encourage distributors to improve their consumption tariffs. As a consumer, a symmetrical tariff is far easier to understand, and a more fair way to price electricity, where my electricity is treated just as valuable as an energy company's energy export or reduction. 

These rebates should be apply to larger consumers and generators as well as mass-market consumers, as ensuring all are appropriately incentivised will lead to the lowest-cost possible distribution system for all consumers in the long-term.

[If you have thoughts on how you have or would consider investing in a battery and the impact getting a more fair price for injecting at peak periods would make on these decisions, feel free to add those thoughts here.]

Additional comment

A strong monitoring and reporting regime to ensure compliance and provide valuable insights is critical across all changes. Complementary Code changes should be undertaken to ease the process of solar and battery installation and upgrades for consumers, and enable them to maximise the size of their contribution to the system.

How does this consultation fit with all the other things?

There are a huge amount of relevant consultations and changes underway in the energy system at the moment. These include:

  • Changes to the permitted voltage range: consultation on this happened late last year, and we are hopeful Government will soon make changes that should result in a doubling of the default limits of how much electricity households can export.
  • Wider Task Force proposals and consultation, including consultation closing 23 April on a proposal to introduce new “mandatory non-discrimination obligations” for gentailers. 
  • Expected rewrite of the Energy Efficiency and Conservation Act 2000, which is being advanced this year and will pave the way for things like smart EV charging.
  • Updates to hundreds of outdated Electricity Safety Regulations, which include outdated rules for things like inverters that add cost and complexity, and can prevent the best technology from being used.
  • The Regulatory Systems (Immigration and Workforce) Amendment Bill, which will enable future updates to Electricity Safety Regulations to be a lot easier, should be advanced later this year.
  • Consumer Data Right Bill, which we submitted on last year and is with Parliament. It seeks to improve consumer access and control over information.

About Rewiring Aotearoa

Rewiring Aotearoa is a non-partisan non-profit organisation that believes electrification has major economic, social, climate and environmental benefits. We represent everyday New Zealanders in the energy system and advocate for an equitable energy transition that does not leave anyone behind. Our mission is to rapidly reduce New Zealand’s emissions, improve cost-of-living outcomes, and increase energy security and resilience by electrifying the millions of fossil fuel machines in our homes, communities, businesses and on-farm. 

Thank you. 

Read moreDownload the document here

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