What you need to know to make a submission

The Electricity Authority Te Mana Hiko (Authority) adopted a new transmission pricing methodology (TPM), which came into effect in April 2023. By providing clearer transmission pricing signals to support timely and well-placed investment, the TPM better supports the electrification of the economy and paves the way for new and emerging technologies, which will bring substantial benefits to consumers in the future. 

What this consultation is about

The purpose of this paper is to consult with interested parties on the Authority’s proposal to amend the transmission pricing methodology (TPM) to: 

1. align the cost inputs for transmission charges with Transpower’s regulation under Part 4 of the Commerce Act so that the approach to valuation and depreciation of assets in the TPM is consistent with the approach used for the annual cost recovery profile under Transpower’s individual price-quality path, as determined by the Commission under Part 4 of the Commerce Act.
2. Standardise the allocators used in the simple method BBC cap (SMBC) formula to ensure a consistent calculation of the cap in any pricing period. 

Clause 12.94A(1)(b) of the Code provides that the Authority may amend the TPM where it is satisfied on reasonable grounds regarding any of the matters in section 39(3) (in which case sections 39(1)(b) and (c) of the Act will not apply to the amendment – the requirement to prepare a regulatory statement and to consult on the amendment and regulatory statement). 

The matters in section 39(3) are: 

1. the nature of the amendment is technical and non-controversial (section 39(3)(a)); or  
2. there is widespread support for the amendment among the people likely to be affected by it (section 39(3)(b)); or 
3. there has been adequate prior consultation so that all relevant views have been considered (section 39(3)(c)). 

The amendment to apply indexation within the TPM is considered a technical and non-controversial change. It is intended to realign the TPM with its original policy objective, which is to adopt the same methodology used in Transpower’s price-quality path. This matter was consulted on in earlier consultations (including on the proposed TPM Guidelines in 2019). Given the Commerce Commission decision to index Transpower’s RAB, it is necessary for the TPM to reflect this change.

The amendment to the SMBC is considered technical and non-controversial as it standardises the allocators used in the SMBC formula to avoid unintended inconsistencies in its application. 

Both amendments relate to policy that was previously consulted on, resulting in the TPM in its current form. We therefore consider that there has been adequate prior consultation on the underlying policy that the amendments seek to implement and all relevant views have been considered. 

Where the requirements of section 39(3) of the Act are met, the Authority is not required to publicise a regulatory statement, or to consult on the relevant amendments or a regulatory statement. 

The Authority nevertheless is consulting on these amendments for feedback, noting that scrutiny of the drafting may result in improvements. However, the Authority considers that the substance of the policy underlying the relevant provisions has been consulted on previously, with the relevant issues addressed in the Authority’s final decision on the TPM Guidelines and the TPM. The focus of this consultation is therefore on the technical drafting of the particular provisions identified as potentially requiring clarification/correction. A regulatory statement has also been provided for completeness.

How to make a submission  

The Authority’s preference is to receive submissions in electronic format (through the Authority’s information provision platform info.ea.govt.nz) using the questions in Appendix B which you can download by selecting Download consultation information or on our website here: https://www.ea.govt.nz/projects/all/tpm/consultation/tpm-technical-amendments-regulatory-asset-base-indexation-and-simple-method-benefit-based-change-cap/.

If you cannot send your submission electronically or would prefer to send a Microsoft Word submission, please email to network.pricing@ea.govt.nz.

Please note the Authority intends to publish all submissions it receives. If you consider that the Authority should not publish any part of your submission, please:

1. indicate which part should not be published,
2. explain why you consider we should not publish that part, and
3. provide a version of your submission that the Authority can publish (if we agree not to publish your full submission).

If you indicate that a part of your submission should not be published, the Authority will discuss this with you before deciding whether to not publish that part of your submission.

However, please note that all submissions received by the Authority, including any parts that the Authority does not publish, can be requested under the Official Information Act 1982. This means the Authority would be required to release material not published unless good reason existed under the Official Information Act to withhold it. The Authority would normally consult with you before releasing any material that you said should not be published.

When to make a submission 

Please deliver your submission by 5pm on Friday ​29 August 2025​.

Authority staff will acknowledge receipt of all submissions electronically. Please contact the Authority network.pricing@ea.govt.nz or 04 460 8860 if you do not receive electronic acknowledgement of your submission within two business days.