We are seeking views from industry and other stakeholders on potential changes to the rules around how Transpower in its System Operator role prepares and publishes information to assist participants to manage security of supply risks.
We are working together with the Electricity Authority on a review of the System Operator Security of Supply Forecasting and Information Policy (SOSFIP), which will be informed by consultation on this Issues Paper. Further consultation on a draft SOSFIP amendment proposal is planned for later in 2025. The Electricity Authority must approve any changes to the SOSFIP.
The two week consultation commenced on Monday, 10 March 2025 and the period for Submissions has now closed. A one-week period for cross-submissions was held and closed on 31 March 2025.
Thank you to everyone who has taken the time to submit submissions and cross-submissions these are published below, once we have worked through all these, we will publish our response document here.
Questions and System Operator Responses
- System Operator using discretion to use a different CSRB buffer
Question
A gentailer participant asked:
We’ve picked up on the below reference in the [consultation] paper:
“The SOSFIP includes a specific discretion to allow the System Operator to determine a different CSRB buffer and make it publicly available. This discretion was included in the flexibility for the System Operator to bring forward access to contingent storage if the operational circumstances make doing so necessary to mitigate an immediate risk to security of supply.”
Could you point us to any particular references at the time the decision was made to incorporate a buffer where it refers to this rationale? Whether in the March 2019 decision paper or elsewhere.
We were interested in whether you could point us to particular references in any of those papers which explain or reference the rationale referred to, i.e. the SO’s discretion to adjust the buffer was intended to allow for bringing forward access to contingent storage if the operational circumstances made doing so necessary to mitigate an immediate risk to security of supply. Where is this set out?
We’re just keen to make sure we understand the SO/EA’s rationale on this as communicated at the time.
System Operator Response
This is the SO’s view on how the discretion should be exercised because (1) it exists in a document concerned with security of supply, and (2) there is a default buffer which should be assumed to be adequate unless there are immediate conditions affecting security of supply. The SO is not aware of any differing rationale for including the discretion.
Please see the 2019 SOSFIP review consultation and decision papers, which set out any further context you are seeking. They can be found on the SOSFIP Consultations page of our website. The Electricity Authority’s decision for the 2019 review, made as part of its simultaneous official conservation campaign review, is available here: Review of regulatory settings for official conservation campaigns 2019 | Our projects | Electricity Authority. We have added this link to our SOSFIP review webpage.
- The tight timeframe for submissions on the Issues paper
Question
A stakeholder queried the tight timeframe for submissions on the Issues paper, and asked that we extend the consultation period for the SOSFIP Issues Paper to 6 weeks to allow for meaningful feedback and participation. It suggested an alternative could be an online feedback session involving the System Operator leading it through the key issues and allowing for verbal feedback.
System Operator Response
The Issues Paper consultation is seeking initial views to inform the scope of the SOSFIP review. Later in 2025 we will be consulting again on a draft SOSFIP amendment proposal consistent with the process required by the Code. That consultation will be more detailed and so consultation timelines will be appropriately longer.
This Issues Paper consultation period is a total of 3 weeks: 2 weeks for submissions and an additional week for cross-submissions. You are welcome to use the full period to submit (rather than strictly following the submit and then cross-submit process). That will give you until Monday, 31 March to send us your feedback. Please see paragraphs 10 and 12 of the Issues Paper which further explain timing and rationale. Thank you for your interest and we look forward to receiving your feedback.
- Timeframes for next steps
Question
A submitter asked “Is it possible to get an update on timeframes / next steps / process for the SOSFIP and contingent storage settings? We’re particularly interested in the timeframes for any decision or next steps on contingent storage settings, including the CSRB buffer and the System Operator’s discretion to change the buffer."
System Operator Response
Our SOSFIP review Issues Paper consultation period ended on Monday this week (31 March). We are currently considering the feedback we have received, and working with the Authority as we consider next steps. We will update all our stakeholders in the coming weeks.
Tuesday 2 April we published our latest security of Supply outlook: It includes (at page 11) an explanation of our current criteria for using the CSRB buffer discretion. That may be useful to you in the meantime.
Submissions
We received 15 submissions listed below.
Contact Energy View Earl Bardsley View Energy Resources Aotearoa View Environment Canterbury View Genesis View Guardians of Lake Hāwea View Harmony View Mercury View Meridian View MEUG View Octopus Energy NZ View Orion View Otago Regional Council View Oji Fibre Solutions (late) View Business NZ Energy Council (late) View Cross Submissions
We received 4 submissions listed below.
Earl Bardsley View Guardians of Lake Hāwea View Meridian View MEUG View