Overview of submissions

Key themes from submitters

High level key themes reflected the diversity of both issues and submitters, and in general acknowledged that a changing environment for participants justifies focus on whether settings remain fit for purpose.

In summary, submissions highlighted that:

  • Ensuring energy affordability through the transition is key and will be difficult to achieve given the level of investment required.
  • There are differing views on the need for measures to support new renewable generation such as contracts for differences and power purchase agreements. There was strong agreement that getting the resource consenting framework is important enabler of the transition.
  • The role of thermal generation through energy transition is important but uncertain, in particular the role of gas as a transitional fuel (gas supply is also uncertain).
  • There are broad concerns about whether current network investment regulatory models are sufficiently flexible and suited towards supporting electrification and decarbonisation.
  • Participants see real barriers to connection to distribution networks, from both load and generation, particularly in relation to the upfront costs of connection.
  • There are mixed views on whether the wholesale market is competitive, and some related concerns raised about retail competition.
  • The risks of early versus later transmission investment have changed and it’s important that transmission access does not end up an impediment to investment in renewables generation. Whether any changes are required to existing regulatory frameworks received mixed views.
  • Better government direction and support is needed to support harnessing the potential of distributed energy resources and flexibility markets developing.
  • In general, stable “macro” policy settings are important to produce investor confidence.

Summary of Iwi/Māori views

5 submitters represented iwi and/or hapū groupings.  While these submissions covered issues raised across the consultation documents, the following were key themes relevant to this discussion document:

  • The transition to more renewable energy future is important to iwi/hapū.

  • Iwi/hapū see the Crown as having a key role in leading this transition and as an “enabler”. One submitter suggested it wanted to see a more ambitious, urgent, and well-coordinated plan from government, another also referenced the time-sensitive nature of measures to support the transition, and another suggested the Crown may need to play a central planning role to get things built where the best resources exist and use all of its “levers” during the transition.

  • Iwi/hapū expect the Crown to meet its Te Tiriti o Waitangi obligations and consider existing settlements. Iwi/hapū expect to work in genuine partnership with the Crown and have aspirations of ongoing engagement with the Crown and MBIE. They expect to not just be “consulted” on things that affect them but also to be actively involved with planning and decision-making and have real opportunities to benefit from the transition, including commercial and economic opportunities.

  • Related to the above, a regional focus is important to iwi/hapū. Submitters often emphasised the importance of specific types of existing generation and infrastructure, and also future opportunities, relevant to the whānau and communities in their own rohe. For at least one submitter, this aligned with explicit expectations of rangatiratanga over local land, water and resources.

  • Iwi/hapū want to ensure intergenerational, multi-dimensional view of issues including cultural and environmental matters. Submitters emphasised that the transition needs to be managed to avoid negative impacts on their people and the environment / natural world (Te Taiao). One submitter saw maintaining energy security and energy equity, and protecting the health and wellbeing of whānau and communities, as important and as a wider influencer of positive outcomes.  Another noted that people needed to be at the centre, and not just decarbonisation and increased energy production.