Greenwood Roche conducts independent assessment of Vector’s Gas Use of System Agreement
Greenwood Roche, led by Partner Brigid McArthur, recently acted as independent assessor to gas industry co-regulator Gas Industry Company Limited, in relation to the compliance of Vector's June 2024 Gas Use of System Agreement (GUoSA) against the Gas Distribution Contracts Oversight Scheme.
The Scheme is a non-regulatory industry governance framework endorsed by the Minister of Energy and Resources in 2012. The Scheme is designed to ensure that core gas distribution contract terms are clear and reasonable, promote market efficiency, and ultimately enhance consumer outcomes. Rather than prescribing a standard form contract, it establishes a set of distribution principles against which publicly available gas distribution arrangements are independently assessed.
Greenwood Roche undertook a detailed review of Vector's GUoSA against those principles, including consideration of the findings from the independent assessment of First Gas' Use of System Agreement completed in 2024. The assessment examined a range of contractual, operational and information management provisions governing the relationship between distributors and retailers. As part of the assessment process, Greenwood Roche attended and observed an industry workshop involving distributors, retailers and other stakeholders to better understand participant perspectives on the proposed agreement and the practical implications of its terms. The assessment concluded that Vector's GUoSA demonstrates substantial alignment with the Scheme principles and is close to full alignment.
The report identified a small number of areas where further refinement or industry discussion may be beneficial over time, including pricing flexibility, time-of-use metering requirements, disconnection and decommissioning arrangements, information management, outage communications and emergency management provisions. Consistent with previous assessments completed under the Scheme, Gas Industry Co also published a commentary note responding to the matters identified in the independent assessment.
The project required detailed analysis of complex contractual, operational and regulatory issues affecting participants across New Zealand's gas distribution sector. Greenwood Roche was pleased to support Gas Industry Co in this important industry initiative and the continued refinement of New Zealand's gas market framework.
