Follow-up re OIA 25 0019 / 25 0027 – Record Retention & Cross-Agency Consistency
SPENCER JONES made this Official Information request to Electricity Authority
Currently waiting for a response from Electricity Authority, they must respond promptly and normally no later than (details and exceptions).
From: SPENCER JONES
Kia ora Electricity Authority OIA Team,
I am writing to follow up on the Electricity Authority’s responses under OIA 25 0019 and OIA 25 0027, which relied primarily on s18(e) (“information does not exist”) and s18(f) (“substantial collation”) in relation to smart-meter safety assessments, health complaints, and incident records.
Since your response, I have obtained WorkSafe New Zealand’s Disposal Authority DA626, confirmed by Archives New Zealand as the operative authority governing Energy Safety inspections, investigations, and summary records, and extended in June 2025.
DA626 confirms that summary-level records, datasets, registers, and aggregated reporting outputs are retained for Energy Safety activity, including audits, inspections, investigations, and compliance monitoring.
In light of this, I request the Electricity Authority to clarify the following:
1. Reconciliation with WorkSafe DA626 Retention
Please explain how the Authority’s position that no relevant records exist is reconciled with the fact that WorkSafe is required to retain summary records under DA626 for:
• inspections and audits (DA626 Class 6); and
• investigations and safety incidents (DA626 Class 7),
where advanced electricity meters (smart meters) are involved.
2. Confirmation of EA Search Scope
Please confirm:
• whether the Authority sought or received any summary-level information from WorkSafe, MBIE Energy Safety, or distributors that would fall within DA626-retained classes; and
• if not, whether the Authority considers such material outside its regulatory consideration under the Electricity Industry Participation Code (including Clause 11.27).
3. 2012 ESR / EA Correspondence
Please also confirm whether:
• the Authority still holds copies of the 2012 ESR–EA correspondence on smart-meter RF exposure and FAQ content (released by PHF Science); and
• if not, under what record-disposal authority those records were destroyed.
This follow-up is made to ensure consistency of record-keeping positions across regulators and to clarify the factual basis for the Authority’s reliance on s18(e) and s18(f).
Kind regards,
Spencer Jones
From: OIA
Electricity Authority
Kia ora Spencer,
Thank you for your request of 22 December 2025, under the Official
Information Act 1982, for the following information:
Since your response, I have obtained WorkSafe New Zealand’s Disposal
Authority DA626, confirmed by Archives New Zealand as the operative
authority governing Energy Safety inspections, investigations, and summary
records, and extended in June 2025.
DA626 confirms that summary-level records, datasets, registers, and
aggregated reporting outputs are retained for Energy Safety activity,
including audits, inspections, investigations, and compliance monitoring.
In light of this, I request the Electricity Authority to clarify the
following:
1. Reconciliation with WorkSafe DA626 Retention
Please explain how the Authority’s position that no relevant records exist
is reconciled with the fact that WorkSafe is required to retain summary
records under DA626 for:
• inspections and audits (DA626 Class 6); and
• investigations and safety incidents (DA626 Class 7),
where advanced electricity meters (smart meters) are involved.
2. Confirmation of EA Search Scope
Please confirm:
• whether the Authority sought or received any summary-level
information from WorkSafe, MBIE Energy Safety, or distributors that would
fall within DA626-retained classes; and
• if not, whether the Authority considers such material
outside its regulatory consideration under the Electricity Industry
Participation Code (including Clause 11.27).
3. 2012 ESR / EA Correspondence
Please also confirm whether:
• the Authority still holds copies of the 2012 ESR–EA
correspondence on smart-meter RF exposure and FAQ content (released by PHF
Science); and
• if not, under what record-disposal authority those records
were destroyed.
We will endeavour to respond to your request as soon as possible and in
any event no later than 11 February 2026, being 20 working days after the
day your request was received.
The response date shown takes into account:
1. Summer holidays (25 December to 15 January)
2. Waitangi Day (6 February 2026)
If we are unable to respond to your request by then, we will notify you of
an extension of that timeframe.
If you have any queries, please feel free to contact me by emailing
[1][Electricity Authority request email].
Ngâ mihi nui,
Alex Shearer (she/her)
Senior Ministerial Advisor
Ngâ mihi nui,
Alex Shearer (she/her)
Senior Ministerial Advisor
Level 7, AON Centre, 1 Willis Street
PO Box 10041, Wellington 6143, New Zealand
www.ea.govt.nz
show quoted sections
From: OIA
Electricity Authority
Kia ora Spencer
I refer to your official information request dated 22 December 2025 for:
Since your response, I have obtained WorkSafe New Zealand’s Disposal
Authority DA626, confirmed by Archives New Zealand as the operative
authority governing Energy Safety inspections, investigations, and summary
records, and extended in June 2025.
DA626 confirms that summary-level records, datasets, registers, and
aggregated reporting outputs are retained for Energy Safety activity,
including audits, inspections, investigations, and compliance monitoring.
In light of this, I request the Electricity Authority to clarify the
following:
1. Reconciliation with WorkSafe DA626 Retention
Please explain how the Authority’s position that no relevant records exist
is reconciled with the fact that WorkSafe is required to retain summary
records under DA626 for:
• inspections and audits (DA626 Class 6); and
• investigations and safety incidents (DA626 Class 7),
where advanced electricity meters (smart meters) are involved.
2. Confirmation of EA Search Scope
Please confirm:
• whether the Authority sought or received any summary-level
information from WorkSafe, MBIE Energy Safety, or distributors that would
fall within DA626-retained classes; and
• if not, whether the Authority considers such material
outside its regulatory consideration under the Electricity Industry
Participation Code (including Clause 11.27).
3. 2012 ESR / EA Correspondence
Please also confirm whether:
• the Authority still holds copies of the 2012 ESR–EA
correspondence on smart-meter RF exposure and FAQ content (released by PHF
Science); and
• if not, under what record-disposal authority those records
were destroyed.
The OIA requires that we advise you of our decision on your request no
later than 20 working days after the day we received your request.
Unfortunately, it will not be possible to meet that time limit and we are
therefore writing to notify you of an extension of the time to make our
decision, to 27 February 2026.
This extension is necessary because your request necessitates a search
through a large quantity of information and meeting the original time
limit would unreasonably interfere with our operations.
We also seek to understand what you are looking for in part two of your
request more clearly, in order to provide you with the most useful
response:
2. Confirmation of EA Search Scope
Please confirm:
• whether the Authority sought or received any summary-level
information from WorkSafe, MBIE Energy Safety, or distributors that would
fall within DA626-retained classes; and
• if not, whether the Authority considers such material
outside its regulatory consideration under the Electricity Industry
Participation Code (including Clause 11.27).
Could you please clarify what you mean by the above part of your request?
Are you looking for information we may hold in respect of any
investigation WorkSafe might have done? Or are you looking for any summary
level information we may hold from the listed agencies in relation to
smart-meters?
Could you please respond with clarification by COP 18 February?
You have the right to seek an investigation and review by the Ombudsman of
this decision. Information about how to make a complaint is available at
[1]www.ombudsman.parliament.nz or freephone 0800 802 602.
If you wish to discuss any aspect of your request with us, including this
decision, please feel free to contact me by reply.
Ngâ mihi nui,
Alex Shearer ([2]she/her)
Senior Ministerial Advisor
[3][IMG]
Level 7, AON Centre, 1 Willis Street
PO Box 10041, Wellington 6143, New Zealand
[4]www.ea.govt.nz
From: OIA <[Electricity Authority request email]>
Sent: Monday, 12 January 2026 3:35 pm
To: SPENCER JONES <[FOI #33368 email]>
Cc: OIA <[Electricity Authority request email]>
Subject: RE: [External] Official Information request - Follow-up re OIA 25
0019 / 25 0027 – Record Retention & Cross-Agency Consistency
Kia ora Spencer,
Thank you for your request of 22 December 2025, under the Official
Information Act 1982, for the following information:
Since your response, I have obtained WorkSafe New Zealand’s Disposal
Authority DA626, confirmed by Archives New Zealand as the operative
authority governing Energy Safety inspections, investigations, and summary
records, and extended in June 2025.
DA626 confirms that summary-level records, datasets, registers, and
aggregated reporting outputs are retained for Energy Safety activity,
including audits, inspections, investigations, and compliance monitoring.
In light of this, I request the Electricity Authority to clarify the
following:
1. Reconciliation with WorkSafe DA626 Retention
Please explain how the Authority’s position that no relevant records exist
is reconciled with the fact that WorkSafe is required to retain summary
records under DA626 for:
• inspections and audits (DA626 Class 6); and
• investigations and safety incidents (DA626 Class 7),
where advanced electricity meters (smart meters) are involved.
2. Confirmation of EA Search Scope
Please confirm:
• whether the Authority sought or received any summary-level
information from WorkSafe, MBIE Energy Safety, or distributors that would
fall within DA626-retained classes; and
• if not, whether the Authority considers such material
outside its regulatory consideration under the Electricity Industry
Participation Code (including Clause 11.27).
3. 2012 ESR / EA Correspondence
Please also confirm whether:
• the Authority still holds copies of the 2012 ESR–EA
correspondence on smart-meter RF exposure and FAQ content (released by PHF
Science); and
• if not, under what record-disposal authority those records
were destroyed.
We will endeavour to respond to your request as soon as possible and in
any event no later than 11 February 2026, being 20 working days after the
day your request was received.
The response date shown takes into account:
1. Summer holidays (25 December to 15 January)
2. Waitangi Day (6 February 2026)
If we are unable to respond to your request by then, we will notify you of
an extension of that timeframe.
If you have any queries, please feel free to contact me by emailing
[5][Electricity Authority request email].
Ngâ mihi nui,
Alex Shearer (she/her)
Senior Ministerial Advisor
Ngâ mihi nui,
Alex Shearer (she/her)
Senior Ministerial Advisor
Level 7, AON Centre, 1 Willis Street
PO Box 10041, Wellington 6143, New Zealand
[6]www.ea.govt.nz
show quoted sections
SPENCER JONES left an annotation ()
Public annotation – extension and clarification request
The Electricity Authority has issued a formal extension under section 15A of the Official Information Act, extending the deadline for a decision on this request to 27 February 2026. The Authority states that responding requires searching through a large quantity of information and that meeting the original timeframe would unreasonably interfere with operations.
In addition, the Authority has sought clarification regarding Part 2 of the request (confirmation of EA search scope and whether summary-level information from WorkSafe, MBIE Energy Safety, or distributors was sought or considered under the Electricity Industry Participation Code).
No refusal has been issued at this stage. Parts 1 and 3 of the request remain unaffected by the clarification query. A substantive decision is now awaited by the revised due date.
From: SPENCER JONES
Dear OIA,
Subject: Clarification – Part 2 (Search Scope Confirmation)
Kia ora Alex,
Thank you for your email.
In relation to Part 2, I am referring to both of the following:
Whether the Authority holds any summary-level information in its possession (whether originating from WorkSafe, MBIE Energy Safety, distributors, or otherwise) relating to inspections, audits, investigations, or safety incidents involving advanced electricity meters (smart meters), including any aggregated reporting outputs or datasets; and
Whether the Authority considers such summary-level material to fall within, or outside, its regulatory consideration under the Electricity Industry Participation Code (including Clause 11.27), regardless of whether the Authority itself conducted the underlying investigation.
This clarification does not expand the scope of the request. It simply confirms that I am seeking confirmation of what information the Authority holds (if any), and how such material is treated from a regulatory consideration perspective.
Kind regards,
Spencer Jones
From: OIA
Electricity Authority
Kia ora,
Thank you for your email.
If you are making a request under the Official Information Act 1982, you
can expect to receive an official acknowledgement email within 5 working
days. This is an automated email and not an official acknowledgement. If
you do not hear from us within 5 working days, please contact us by
calling +64 4 460 8860.
If this is a general enquiry, please email [email address].
Ngā mihi,
Electricity Authority
Te Mana Hiko
Level 7, AON Centre, 1 Willis Street
PO Box 10041, Wellington 6143, New Zealand
[1]www.ea.govt.nz
"The information contained in this transmission is confidential. It is
intended for the named addressee only. If you are not the named addressee
you may not copy, distribute or take any action in reliance upon this
transmission."
References
Visible links
1. http://www.ea.govt.nz/
From: OIA
Electricity Authority
Kia ora Spencer
Thank you for confirming you are seeking summary-level information rather than records of Worksafe investigations. The question we asked was not intended to extend the scope of your original request which remains limited to the entities you listed (WorkSafe, MBIE Energy Safety, or distributors) and information that falls within DA626-retained classes.
To the extent you are seeking further information by adding 'or otherwise' to the list of entities, or by seeking information relating 'to any inspections, audits, investigations, or safety incidents involving advanced electricity meters (smart meters)' that is not related to information not related to the DA626-retained classes, this is a new OIA request.
We would like to provide you with reasonable assistance, but in order to do so, we need you to narrow the scope of your request further. As it stands, this part of your request is very broad and would require substantial manual collation and research to find and collate information in scope of this request.
Could you please refine your request to identify the specific additional entities you are referring to when you state 'or otherwise'? We also ask that you more clearly identify what is meant by ‘inspections, audits or investigations involving advanced electricity meters', and that you add a specific timeframe to this part of your request.
Please do not hesitate to contact me if you have any questions.
Ngā mihi nui,
Alex Shearer (she/her)
Senior Ministerial Advisor
Level 7, AON Centre, 1 Willis Street
PO Box 10041, Wellington 6143, New Zealand
http://www.ea.govt.nz/
show quoted sections
From: OIA
Electricity Authority
Kia ora Spencer
Please see attached
Ngâ mihi nui,
On behalf of the Senior Ministerial Advisor
show quoted sections
From: SPENCER JONES
Dear OIA,
Tēnā koutou,
Thank you for your response dated 27 February 2026.
For the avoidance of doubt, I confirm that I am not expanding the scope of my request.
My intention is limited and precise.
Please treat this as clarification only, not as a new or broadened request.
The scope is confined strictly to the following two points:
1. Summary-Level Information Held or Received
Confirmation of whether the Authority holds, or has received at any time, any summary-level information from WorkSafe, MBIE Energy Safety, electricity distributors, or any other relevant agency concerning:
• inspections,
• audits,
• investigations, or
• safety incidents
relating to advanced electricity meters (smart meters).
This includes aggregated, high-level, or summary data only. It does not require detailed case files or underlying investigative records.
2. Formal Information-Sharing Arrangements
Confirmation of whether any formal information-sharing arrangements, memoranda of understanding (MOUs), statutory protocols, or structured reporting mechanisms exist between the Authority and:
• WorkSafe,
• MBIE Energy Safety, or
• electricity distributors
in respect of safety information concerning advanced electricity meters.
This clarification is intended to ensure the request remains narrow, manageable, and clearly defined, and to avoid any unnecessary procedural reframing.
I appreciate your confirmation that this clarified scope will be assessed under the current request framework and not treated as a materially expanded or new request.
Kind regards,
Spencer Jones
SPENCER JONES left an annotation ()
Public Annotation – Clarification of Scope (Request #33368)
For transparency, I have provided a clarification to the Electricity Authority regarding the scope of this request.
To be clear:
I am not expanding the scope of the original request.
My clarification narrows the focus to two precise issues only:
1. Whether the Authority holds, or has ever received, summary-level information (including aggregated or high-level data) from WorkSafe, MBIE Energy Safety, electricity distributors, or any other relevant agency concerning:
• inspections,
• audits,
• investigations, or
• safety incidents
involving advanced electricity meters (smart meters).
This does not seek detailed investigative files or case-level documentation. It is limited to confirmation of summary or aggregated information only.
2. Whether any formal information-sharing arrangements exist between the Electricity Authority and:
• WorkSafe,
• MBIE Energy Safety, or
• electricity distributors
regarding safety information connected to advanced electricity meters.
This clarification is necessary to avoid procedural drift and to ensure the request remains narrow, precise, and manageable under the Official Information Act 1982.
The purpose of this request is to understand the regulatory architecture — specifically:
• Whether safety information flows formally between agencies,
• Whether summary-level safety data is available to the Authority,
• And whether any structured oversight mechanisms exist in relation to smart-meter safety matters.
The Electricity Authority has indicated that part of the request would be treated as a new OIA due to perceived scope expansion. This annotation confirms that no expansion is intended. The request is confined strictly to confirmation of summary-level holdings and the existence (or absence) of formal information-sharing arrangements.
Clarifying scope at this stage ensures that the request can be processed efficiently and reduces the risk of unnecessary refusal grounds such as “substantial collation” or mischaracterisation of intent.
I will await the Authority’s response within the statutory timeframe.
SPENCER JONES left an annotation ()
Public Annotation – Governance and Regulatory Accountability Context
For completeness and public transparency, I wish to explain why this clarification matters from a governance perspective.
The Electricity Authority has confirmed that WorkSafe’s Disposal Authority (DA626) applies only to WorkSafe and does not impose record-retention obligations on the Authority.
That is legally correct in a narrow sense.
However, the broader public-interest issue is not record retention in isolation. It is whether:
• Safety-related information concerning advanced electricity meters (smart meters),
• Including inspection summaries, audit findings, investigation outcomes, or aggregated incident data,
• Is formally transmitted to, held by, or considered within the Authority’s regulatory oversight framework.
If no summary-level information is held, and no formal information-sharing arrangements exist, this raises structural governance questions about:
• Cross-agency coordination,
• Regulatory visibility of safety matters,
• And whether oversight of advanced meter deployment operates in segmented silos rather than through integrated monitoring.
The clarification provided is intentionally narrow and manageable. It seeks only confirmation of:
• The existence (or absence) of summary-level information; and
• The existence (or absence) of formal information-sharing mechanisms.
This is a governance architecture question, not a request for detailed case files.
The public interest lies in understanding how regulatory responsibilities interact across agencies in areas where:
• Technology deployment intersects with safety considerations; and
• Multiple statutory bodies hold adjacent responsibilities.
I will await the Authority’s response within the statutory timeframe.
SPENCER JONES left an annotation ()
Public Annotation – Regulatory Oversight Context (Electricity Industry Participation Code, Clause 11.27)
This request also relates to the Authority’s responsibilities under the Electricity Industry Participation Code 2010.
Clause 11.27 of the Code governs requirements relating to advanced metering infrastructure and associated obligations on participants. While the Code does not itself create health and safety enforcement powers (which sit primarily with WorkSafe and MBIE Energy Safety), it forms part of the regulatory environment under which advanced electricity meters are deployed and operated.
The clarification now provided is designed to determine:
1. Whether the Authority receives or holds any summary-level safety information (for example, aggregated incident data or inspection summaries) concerning advanced electricity meters; and
2. Whether any formal information-sharing arrangements exist between the Authority and:
• WorkSafe,
• MBIE Energy Safety, or
• Electricity distributors,
regarding safety matters associated with those meters.
This is not an attempt to expand the scope of the request.
Rather, it seeks to understand whether:
• Regulatory oversight under the Code operates with visibility of safety-related information held by adjacent agencies; or
• Oversight functions are structurally compartmentalised without formal cross-agency data flow.
Understanding whether such summary-level information is held, or whether formal information-sharing arrangements exist, is directly relevant to assessing:
• The completeness of regulatory monitoring frameworks;
• The interaction between market regulation and safety regulation; and
• The robustness of governance structures surrounding advanced metering infrastructure.
This clarification keeps the request narrow and focused while ensuring the regulatory context is properly understood.
From: OIA
Electricity Authority
Kia ora Spencer,
Thank you for your email.
As per our previous correspondence:
• on 11 February 2026 we asked you to refine your request of
22 December 2025
• you provided a response on 11 February 2026
• on 18 February 2026 we noted that your response
significantly expanded the scope of your original request and would be
treated as a new OIA request without further refinement.
• as we did not receive a response to our 18 February 2026
request for further refinement, on 27 February 2026 we confirmed the
expanded scope of the request would be treated as a new OIA with a
statutory due date of 11 March 2026.
We have decided to extend the 11 March 2026 date until 8 April 2026. This
extension is necessary because your request necessitates a search through
a large quantity of information and meeting the original time limit would
unreasonably interfere with our operations.
We ask again that you refine your request as set out in our email 18
February 2026:
Could you please refine your request to identify the specific additional
entities you are referring to when you state 'or otherwise'? We also ask
that you more clearly identify what is meant by ‘inspections, audits or
investigations involving advanced electricity meters', and that you add a
specific timeframe to this part of your request.
Note that without further refinement (as requested in our letter of 18
February) it is possible the request will be refused under section 18(f)
because of the research and collation involved.
Could you please respond by COP 13 March 2026.
If you have any queries, please feel free to contact me by emailing
[1][Electricity Authority request email].
Ngā mihi nui,
Alex Shearer (she/her)
Senior Ministerial Advisor
Level 7, AON Centre, 1 Willis Street
PO Box 10041, Wellington 6143, New Zealand
www.ea.govt.nz
show quoted sections
From: SPENCER JONES
Dear OIA Electrical Authority (EA),
Subject: Refinement of OIA request – Follow-up re OIA 25-0019 / 25-0027
Kia ora Alex,
Thank you for your email and for confirming the extension of the response timeframe.
In order to assist the Authority in processing the request, I am happy to provide clarification and refinement of the scope.
For the purposes of this request:
1. Entities
Where the request refers to “retailers, metering providers, network operators, or otherwise”, the entities of interest are:
• Electricity retailers
• Metering equipment providers (MEPs)
• Electricity distribution businesses (EDBs) / network operators
• Metering data service providers
• Any other regulated participant operating within the Electricity Authority’s jurisdiction under the Electricity Industry Participation Code.
2. Definition of “advanced electricity meters”
For clarity, the phrase “advanced electricity meters” refers to:
Advanced Metering Infrastructure (AMI), commonly referred to as “smart meters”, including associated metering communications systems and data management systems used to remotely collect electricity consumption data.
3. Types of oversight activity
For the purposes of this request, “inspections, audits, or investigations” refers to any regulatory or compliance-related activity undertaken by the Electricity Authority or on its behalf, including but not limited to:
• regulatory compliance audits
• inspections or reviews of metering systems or metering data management processes
• compliance monitoring activities
• investigations into metering performance, metering data accuracy, or regulatory compliance
• reviews or reports relating to metering infrastructure governance.
4. Timeframe
To assist with the collation of information, the timeframe for this request may be limited to:
1 January 2018 – present
If a narrower timeframe would materially assist the Authority in responding to the request, I would be happy to discuss this.
5. Form of information
If the information exists in multiple document types, I would be grateful if it could be provided in the form most readily available (for example reports, document schedules, summaries, or lists of relevant records).
I hope these clarifications assist the Authority in processing the request. If further refinement would help reduce the research burden while still allowing the information to be identified, I would be happy to discuss this.
Kind regards,
Spencer Jones
SPENCER JONES left an annotation ()
Annotation – Context and Significance of this Request
This request forms part of a broader research project examining how New Zealand regulatory agencies oversee advanced electricity metering systems (commonly referred to as “smart meters”).
The request specifically seeks information about regulatory oversight activities such as inspections, audits, or investigations relating to advanced metering infrastructure and associated data governance. These records are important because they help demonstrate how regulatory oversight is exercised in practice.
Under the Official Information Act, government agencies are expected to create and maintain records documenting their regulatory activities. The Public Records Act similarly requires agencies to maintain full and accurate records of their business activities so that government decisions can be understood and scrutinised.
Requests of this type therefore help clarify how regulatory oversight operates in real administrative systems rather than only in policy documents. The resulting records may include audit reports, investigation files, compliance monitoring documents, or communications with regulated entities.
This request is also connected to several other OIA requests examining regulatory oversight, scientific advice, and data governance relating to advanced electricity infrastructure. Together these requests aim to reconstruct the administrative decision-making framework surrounding smart meter governance in New Zealand.
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SPENCER JONES left an annotation ()
Public annotation:
The agency has acknowledged this follow-up request concerning record-retention practices and cross-agency consistency arising from earlier OIAs. No substantive response has yet been provided. A response is awaited within the statutory timeframe.
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