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Ā Mātou Tāpaetanga

UDL draws on over twenty years of operations to make submissions on new legislation and consultations carried out by regulatory, government and non-government agencies.  These may relate to our areas of expertise such as electricity, gas, water and installation of fibre on shared property and also the benefits of a free and independent dispute resolution service. Some of these submissions are catalogued below.

You can request information on our other submissions by contacting

UDL Submissions

  • The EA was seeking submissions on eight options to support and promote consumer comparison and switching between electricity retailers and plans. 

    Read the full UDL submission here.

  • The Electricity Authority Te Mana Hiko’s was seeking submissions as part of their review of electricity retail market monitoring under clause 2.16 of the Electricity Industry Participation Code 2010.

    Our submission summary:

    We believe the proposed methods of gathering complaints and related data will assist the Authority in meeting its statutory objectives of promoting competition, reliability and promoting and protecting the interests of domestic and small business consumers, in relation to their electricity supply. Our comments have been focused on areas where the collection of information might be improved, including opportunities where it may better align with similar information collected by UDL.

    Read the full UDL submission here.

  • The Ministry of Housing and Urban Development was seeking feedback on proposed amendments to the Retirement Villages Act 2003 and its associated regulations and code which aim to protect the interests of retirement home residents.

    UDL often works with retirement villages through our Energy Complaints Scheme, as many retirement villages qualify as secondary networks and are therefore members. We used our expertise in this area, as well as our knowledge of dispute resolution, to make several comments on the proposal, such as:

    • Encouraging the establishment of an independent dispute resolution scheme as the preferred mechanism for resolving disputes between village residents and village operators.
    • Proposing specific procedures that would assist the scheme in delivering an effective service.
    • Suggesting specific jurisdiction limits that clearly define the scope of the scheme, drawing from the principles in UDL’s general and scheme rules.
    • Suggesting that the scheme be free for consumers to ensure no financial barriers restrict access.
    • Noting that retirement village energy networks often fall under our scheme already, and in many cases are already members, so residents should likely be made aware of their existing rights to bring complaints to UDL.

    Read UDL's submission on the Review of the Retirement Villages Act 2003 here.

  • MBIE was seeking feedback on proposed amendments to the Electricity (Hazards from Trees) Regulations 2003. UDL regularly refers to these regulations when dealing with tree-based complaints, and as such were well positioned to make a submission. We used this expertise to make several comments on the proposed amendments, such as:

    • The need to clarify to consumers their position in regard to ownership of service lines.
    • The need to consider how consumers can be impacted by outages caused by inadequate tree maintenance. 
    • Provisions must be made to ensure that any regulations respect Te Tiriti o Waitangi.
    • Offered expert advice on technical aspects such as right to access, judicial precedent, and potential complaints. 
    • Highlighted UDL's expansive history in tree regulation-based dispute resolution.

    UDL frequently deals with tree-regulation cases, and as such found it necessary to make produce a comprehensive submission. UDL submitted a 22 page response to the MBIE discussion document that catalogued our thoughts on the proposed amendments with reference to how previously considered cases would be impacted by regulation changes.

    Read the Review of the Electricity (Hazards from Trees) Regulations 2003 - May 2023.

  • MBIE formed the Energy Hardship Expert Panel to recommend policy priorities and actions to government that would alleviate energy hardship, and provide expert advice to policy makers. They produced a discussion paper outlining the key areas for which they required feedback. The purpose of this feedback was to identify the key areas of energy hardship and propose solutions.

    UDL responded in order to provide the perspective gained over two decades of energy dispute resolution. Our comments were:

    • Any initiatives taken must be supported by comprehensive education for vulnerable consumers.
    • Suggested methods for more effectively monitoring healthy homes standards, which often reduced energy use.
    • Provide additional assistance for tenants due to the vulnerability of renting.
    • Strengthen energy related social services to ensure consumers have the necessary support networks.
    • We acknowledge the reality of energy hardship for lower socio-economic consumers and the need to address the systemic issues responsible. 

    Read Te Kore, Te Pō, Te Ao Marama | Energy Hardship – the challenges and a way forward - April 2023

  • The Commerce Commission asked for submissions during their review of telecommunications retail service quality. They released a customer service consultation paper addressing a perceived weaknesses in customer service in telecommunications and opened up public submissions to respond to this paper.

    Our submission was based upon on the experience obtained in operating several consumer facing utility dispute schemes.

    • Stressing the need for internal and external reporting to determine the satisfaction of customers and reasons why.
    • Noted the importance of creating flexible reporting metrics for organisations of different size.
    • Noted areas of similarity within the energy industry that may prove successful if transferred.
    • Recognised the subjectivity of 'resolving disputes' and the need to flexibility in determining success.
    • Supported the Commerce Commission's claim that a dashboard ranking provider customer service performance should be mandatory on telecommunications companies websites.

    These comments were all made with reference to UDL's experiences in consumer dispute resolution.

    Read the UDL submission on Retail Service Quality: Customer Service - March 2023

  • The Electricity Authority sought feedback on a variety of options to better manage residual supply risk in winter 2023. They asked stakeholders like UDL to make submissions considering these options and sharing their thoughts.

    We responded to section regarding compensation payments for power cuts. We submitted that:

    • We appreciate that providers would be incentivised to ensure sufficient electricity is provided to consumers.
    • However, the existing laws would only offer payment to consumers with a unique Installation Control Point (ICP).
    • This would therefore likely be most detrimental to independent retailers. 
    • Moreover, the relationship between the proposed compensation payouts and the Consumer Guarantees Act would create difficulties.

    Read the UDL submission on Driving efficient solutions to promote consumer interests through winter 2023 - December 2022


  • In early 2022, the Finance and Expenditure Committee called for public submissions on the Water Services Economic Efficiency and Consumer Protection Bill.

    The bill aimed to restructure New Zealand's water network, transferring operation of NZ water services from local councils to newly formed public entities.

    UDL's submission referred to parts 3 and 5, and schedule 2. We made recommendations on:

    • The necessary service codes for operation of these entities.
    • The quality of complaint processes and complaint reporting required.
    • The availability of a mandatory dispute resolution service.
    • That this service be free, independent, and fair.

    UDL aimed to use its dispute resolution experience to recommend bill alterations that would allow the chosen dispute resolution service to operate more effectively. 

    Read the UDL submission on the Water Services Economic Efficiency and Consumer Protection Bill - February 2022