Vector Electricity Asset Management Plan— 2020 Update
In addition to passenger vehicles, Auckland Transport’s Low Emission Bus Roadmap targets an entirely low-emissions bus fleet by 2040. Trials have already begun with 11 electric buses expected on the road by the end of 2020. Vector and AT will carry out a feasibility study to assess the impact of a fully electric bus fleet on the Auckland electricity network, and to identify opportunities where innovative energy technologies could be deployed to facilitate the transition and help avoid large network upgrade costs.
2.4 Better outcomes through regulatory and policy alignment
Here we present Vector’s position on regulatory and policy related matters that have significant potential to improve network reliability, security and resilience. Vector continues to engage with stakeholders on all these issues in a proactive and committed manner. We believe that some regulatory settings are inconsistent with other policy and regulatory goals – including to enable Auckland growth, as well as to ensure long term reliability is delivered affordably and in partnership with communities and stakeholders. Some of the regulatory issues below – such as the current vegetation management regulation, are significantly misaligned with the efficient delivery of reliability. VEGETATION MANAGEMENT Vegetation management regulations are currently under review by the Ministry of Business Innovation and Employment (MBIE) – and we support this initiative and its continued urgent progression. Current regulations present significant issues. For example, in some cases the narrow growth limit zone prescribed does not align with minimum approach distances (MAD) prescribed by health and safety legislation. Accountabilities are not appropriately balanced within the current regulatory framework and do not align with parties’ abilities to manage risk. We support regulations that respond to the drivers of risk, that allow a preventative approach, and which align incentives with good health and safety practices and reliability outcomes. As we expect an increase in extreme weather events linked to climate change, and as we rely on electricity more through the electrification of transport and industrial process heat, it is critical that vegetation management regulations respond to the key drivers of risk. As stated in the 2014 Opus report, a review of the effectiveness of the Electricity (Hazards from Trees) Regulation 2003 3 , “of all reported tree related incidents, fall zone and overhanging trees have the most significant impact on electricity network reliability, although these trees are not covered under the current regulations”. We therefore support an approach which accounts for the factors that contribute to the risk posed by a tree – including, critically, the fall zone. A risk- based approach could support a more efficient response by targeting resource towards trees that most require a response, whilst allowing trees to grow which do not pose a risk. By only prescribing a narrow distance that trees’ branches must be from lines, the current framework limits the scope for prevention and efficiency. There is an opportunity for regulation to better protect security of supply and health and safety, to gain efficiency, to create a better experience for customers. We also believe there is an opportunity to support these outcomes through preventive planting guidelines – to prevent trees from being planted where they will inevitably grow into lines in the future. Lastly, cost recovery for electricity distribution businesses (EDBs) is determined by whether the cut is the first or a subsequent cut. This approach creates administrative burden and does not clearly reflect considerations which we believe should be central in determining cost recovery – such as affordability and health and safety. OUTAGE RESPONSE We support the proposed, “Land Transport (Vehicles Responding to Electrical Emergency) Amendment Bill” 4 allowing lines companies’ response vehicles to use flashing lights to move through traffic and swiftly respond to electrical emergencies. Under current land transport rules, emergency response vehicles such as the ambulance or fire brigade can use their lights to respond quickly to an accident. However, when that accident involves downed electrical lines from a vehicle striking a power pole, the emergency response crews must wait for our lines crews, who are often stuck in traffic, to arrive and turn off the power flowing through the downed lines before they can safely perform their life-saving work. Similarly, in the case of customers who are medically dependent on electrical machines, the response time for getting the power back on in a power outage is critical. The proposed bill addresses the use of vehicle lights to respond to those electrical emergencies with an associated health and safety issue. However, following the proposed pathways to decarbonising New Zealand’s economy will make consumers lives and businesses more dependent on an uninterrupted supply of electricity. If response crews had access to flashing lights in every power outage situation where congestion is a problem, we could reduce response times and speed up power restoration considerably. CUSTOMER SERVICE LINES We support the Ministry of Business, Innovation and Employment’s (MBIE’s) review of the regulations around customer service lines, including discussions about the treatment of right of way poles. The legislative treatment of customer service lines has changed over time, contributing to inconsistency in how assets are treated by different EDBs and a lack of clarity around responsibilities in some cases. In this context, it is our experience that customers often do not know they own these assets or what their responsibilities are (and often dispute responsibility when this is raised). This is concerning as the assets age and require maintenance. Limitations around property access rights and cost recovery restricts an EDB’s ability to undertake proactive maintenance of customer service lines.
3 https://www.ena.org.nz/assets/Uploads/Opus-Tree-Regs-Report-May-2014-Final.pdf
4 https://www.parliament.nz/en/pb/bills-and-laws/proposed-members-bills/document/52HOH_MEMBILL157_1/land-transport-vehicles-responding-to-electrical-emergency
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