Levi Gibbs

Published: July 19, 2023

Submitting To: Commerce Commission

Issue for Business: The Commission's draft decision largely retains the current methodology. This may not be prudent considering the evolving needs of electrification. There are instances where the Commission proposes changes that are retrograde steps, such as reductions to the weighted average cost of capital (WACC) percentiles for EDBs, which seem questionable given the need for investment in decarbonisation and the transition away from being less dependent on thermal generation. The WACC impacts financiability by acting as a building block for the rate of regulated return – the return that a regulated network can earn on investments. Implementing a steady state or incremental approach, in this context, could possibly slow electrification, and thus jeopardise the country’s energy transition. Insufficient allowances for network companies would likely result in a slower and impeded transition, making it more challenging for the country to meet its international commitments to achieve net-zero emissions within the designated timeframe.