It wants a disbanding of the "vertical integration" of the three state-owned power companies, Meridian, Genesis and Mighty River Power
Their generation side should be split off from the retail side, Comalco says, with the retail companies staying as SOEs.
No mention is made of privately owned Contact which, with its primarily thermal generation and 380,000 retail customers, was one of the big winners of the recent dry winter and low lake levels.
By operating its thermal plants at full capacity, it was able to sell power to rival companies at high spot market prices.
Generators relying on hydro dams did not generate as much electricity as they wanted to, as they were constrained by low water levels in their storage lakes.
Generators having their own retail arms were able to shield their customers from high prices.
Around 90 per cent of electricity going into the market came from the four big companies.
"The recent electricity problems were not surprising," says the Comalco submission.
"Moderate stress [low inflows] exposed the consequence of more than a decade of poorly designed arrangements, designed by generators to advantage generators, without reasonable regard to the interests of consumers, large and small."
New Zealand's poorly designed electricity market had undermined the country's reputation as a place to do business, said Comalco.
"The performance of the electricity market this year does not encourage investment in energy-reliant industries."
Power to the People Supplement
Energy Efficiency and Conservation Authority
