Nsw gas Change of User Paper
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- Bu səhifədəki naviqasiya:
- In Situ CoU and Scheduled Reads
- No Actual Read Available
- Reconnection Associated with CoU
Title: NSW/ACT Gas Change of User (CoU) Future State
In anticipation of NSW/ACT moving to align with other jurisdictions which operate according to the FRC B2B/B2M system architecture, CSV format and FRC Hub Terms and Conditions; this paper outlines the proposal of how the Change of User (CoU)/Transfer process will operate in the new B2B/B2M environment. With regard to the CoU/Transfer processes adopted in SA, Vic, QLD and NSW and the experience gained over a number of years in operating in each of these markets, the CoU process put forward here is a combination of various aspects of these CoU/Transfer processes, which is expected to provide an optimal solution for the CoU process for NSW gas. Jemena feedback Pre-existing B2B and B2M Jemena notes that the paper states that this proposal relates to ‘the move to a Business to Business (B2B) and Business to Market (B2M) transactions within the NSW gas market’. It is of concern that the document is premised on the assumption that B2B and B2M transactions do not currently exist in the NSW and ACT jurisdictions. Proposing a B2B and B2M regime in an environment where none exists provides many benefits to offset the cost of implementation that are not present where an existing regime is present, as is the case in the NSW and ACT jurisdictions. Benefit and longevity of change considering Harmonisation By way of Background, the paper makes reference to a set of proposed processes that are to be used by market participants in managing the transfer of consumers between retailers (COU). As the COU process is primarily the means by which consumers are transferred between retailers, Jemena in principle supports any improvement to the process used by retailers which provides an efficient and effective outcome for consumers. What is unclear is how the proposed process relates to the harmonisation of national B2B and B2M processes. The processes are purportedly only applicable to NSW and ACT, which would appear to limit their value given the B2B roadmap would see processes harmonised within a timeframe that does not allow any return of significance from any such investment prior to processes potentially changing again to achieve national harmonisation. If the processes proposed are in fact intended to be of the form that are harmonised nationally, their application to other states and jurisdictions should also be assessed in order to confirm this. As Jemena would be required to implement a nationally harmonised processes under AEMO’s Harmonisation project by July 2015, the concern is whether an additional change prior to this will have sufficient longevity to satisfy a cost/benefit test, and the risk of delay the additional work might have on the time required to implement full harmonisation. The cost, benefit and timing of this change should be considered in conjunction with the impact of the Harmonisation project in order to determine whether the change should proceed. In particular benefit analysis should focus on NSW and ACT consumers in order to understand whether those parties who would ultimately fund the distributor’s costs in implementing the change receive a net benefit as a result.? Envestra feedback Suggest amending the sentence to say: With regard to the CoU/Transfer processes adopted in SA, Vic, QLD and NSW and the experience gained over a number of years in operating in each of these markets, the CoU process put forward here (by the retailers) is a combination of various aspects of these CoU/Transfer processes, which is expected to provide an optimal solution for the CoU process for NSW gas. Collective Retailers response to NWO feedback It is acknowledged there are both B2B and B2M transactions operating in the NSW gas market. Refer to the update in the ‘Background’ for clarification. As discussed at the NSW B2B Working Group meeting on 26th October, this document is the Retailer view of how the CoU process will operate in the future. In order for these changes to come about the normal Retail Market Procedure change management process will need to be undertaken. The CBA for the NSW Project is based on the system architecture and transactions as per the Scoping Matrix and accompanying Scope Documents. It is expected the Gas Road Map for Vic, SA and QLD will be informed by the NSW B2B Project (and this paper), with opportunities of harmonisation identified. There is no conflict between the Road Map and the NSW B2B project.
Currently CoUs in NSW are allowed to complete on the provision of an estimated meter read. In line with other jurisdictions it is expected, with the introduction of B2B and B2M, transfers will only complete on the provision of an actual meter read. This reduces the risk of under/overcharging of customers by retailers and reduces the retailer’s wholesale exposure. Jemena feedback Under section 2, Actual Reads, The paper proposes that transfers only occur on actual reads and not those that are estimated. Two reasons are provided to justify this position. The first proposition is that the use of actual reads will reduce the risk of under or over charging of customers by retailers and secondly, will reduce the retailer’s wholesale exposure. In response to the retailers’ comments, Jemena notes: • Whether an estimate is equal to, marginally higher or marginally lower than an actual read, the consumer will have the liability for the actual consumption when at some point in the future an actual read is taken. As the estimation methodology has no regard to whether a transfer is occurring or not, there is no implicit shift towards one retailer over another. The issue would therefore seem to be a balance between the short term allocation of the marginal discrepancy between an actual and estimate compared to the consequence of an expected transfer failing because an actual read was unable to be taken. It is unclear why the former is considered a larger issue for then consumer than the latter. • In terms of wholesale exposure, a retailer’s withdrawal from the network is based in part on the same estimate that would be used to transfer a consumer. It is therefore unclear how a transfer on estimate would have any wholesale consequence for a retailer. Note that estimated meter readings are based on recent consumption at a particular meter. If transfers are to be normally performed only on actual reads, it should be noted that there are situations in which industry will need to permit the use of estimate meter readings for COU or change of user on move-in (COUMI) transactions in order to ensure correct operation. For instance, the ability to use estimated meter reads for COU transactions during Retailer of Last Resort events and during any bulk transfer processes that are initiated under chapter 7 of the Procedures is required in order to give effect to the prescribed methodologies that respond to those events.. Envestra feedback Envestra accept the proposal. Collective Retailers response to NWO feedback In addition to the issues raised by the retailers above, there remain concerns with transfers occurring on estimations. Agreed, an estimated transfer read will eventually see the customer liable at some point when an actual read is taking. However, the over/undercharging could extend beyond the transfer date and this has financial impacts on the current retailer. In cases where multiple previous reads prior to the transfer completion date were estimated (could be up to twelve months) the discrepancy could be significant. The customer could be disadvantaged for example by overcharging and dispute their invoices with their new retailer, the customer may also dispute their invoices with the previous retailer making adjustments between retailers complicated. It is also important Industry participants consider their obligations are met in accordance to the NGL and the NERR which prove challenging to adhere to if we do not transfer on actual reads. For example per the NERR under section 31 Overcharging advises; Where a small customer has been overcharged by an amount equal to or above the overcharge threshold, the retailer must inform the customer accordingly within 10 business days after the retailer becomes aware of the overcharging. Note—this sub rule is a civil penalty provision for the purposes of the Law. (See the National Regulations, clause 6 and Schedule 1.) Another example per the NERR under 21 Estimation as basis for bills advises the retailer must include an adjustment on the later bill to take account of any overcharging of the customer that has occurred. It is acknowledged transfers will occur on estimated reads in a RoLR event. The reason for this is the volume of sites which would need to have a read on the date of the RoLR event, to affect the transfer, could not all be done on that date. It has been discussed on numerous occasions as part of the B2BWG that RoLR related process are not in current scope of the project.
Where the proposed date on the in situ transfer request is the next schedule read date, as per the provision of basic meter reading data, the distributor or meter data agent may read the meter +/- 4 days of the scheduled read date and provide this read for the transfer as of the date the read was taken. Jemena feedback Jemena does not support the +/-4 day window for in situ transfers as it relates to the concept of a deemed read. Please refer to the response on deemed reads below. Envestra feedback Envestra accept the proposal. Collective Retailers response to NWO feedback Refer to the response under Deemed Reads – Move-in
The CoU process requires a proposed change date to be provided on the transfer request. This is the date it is anticipated, an actual basic meter read will be provided which will allow the CoU to complete. For the CoU move –in process in SA, the provision of the actual read for transfer completion allows for an actual read obtained up to 10 calendar days prior to the move-in/transfer date to be used as the transfer read. The read will be deemed to have been taken on the proposed change date in the transfer request. In Victoria and QLD if there is a read 10 days prior to or 4 days post the proposed date in the transfer request, the transfer will complete on the date of the read in the -10/+4 period. The proposal is to adopt a combination of the SA, Vic and QLD processes such that; if an actual read is available -10/+4 days from the proposed change date in the transfer request, the transfer will deemed to have occurred on the proposed change date not the date the read was actually taken. The rationale being the property has been vacant (this is a move-in scenario), the consumption would be negligible (pilot lights) and there is minimal, if any, risk of overcharging to the customer. Should there be no read within the allowable period of -10/+4, the transfer will complete as per the date of the special read as requested by the retailer.
Jemena feedback Jemena supports the completion of a customer transfer on the date a meter reading is undertaken. Jemena does not support the provision of deemed reads as occurs in South Australia This is because the provision of deemed reads means that a retailer will be provided with a distorted and inaccurate meter read for a delivery point. To clarify further, if an actual meter read is performed on one day, but deemed to have been read up to ten days prior to the transfer date, the deemed read provided to the retailer will not accurately reflect the actual consumption at the customer’s delivery point on the date of the deemed read. Any deeming of a meter read creates an inaccuracy and diversion from reality regarding what actual consumption exists at a particular DPI at a particular point in time. In addition, Throughput is measured by the difference between two meter reads, corresponding to the time period between those reads. Transportation charges therefore apply to the measured throughput between the times of measurement. Any deeming of reads would create a disconnect between what has actually occurred and is invoiced for, compared to what the market has deemed to have occurred for the purposes of a market transaction. Note: Jemena seeks clarification on the following point ‘Should there be no read within the allowable period of -10/+4, the transfer will complete as per the date of the special read as requested by the retailer.’ This point seems to contradict the retailer concept of a meter read occurring within an allowable period. Envestra feedback Envestra accept the proposal. Collective Retailers response to NWO feedback The deemed read process has operated since FRC in SA with no perceptible adverse impacts to customers, retailers or the distributor. As indicated previously the rationale being the property has been vacant (this is a move-in scenario), the consumption would be negligible (pilot lights) and there is minimal, if any, risk of overcharging to the customer. To clarify the ‘note’ from Jemena; where a move-in transfer has been requested, the distributor will check if there is an actual read -10/+4 days from the proposed date in the transfer request. If there is no actual read or no read about to be taken within the timeframe, the distributor will arrange a special read to be taken for the proposed date. This is still in line with the allowable period.
For in situ CoUs a retailer may request a transfer to complete based on a special read. A service order will be raised nominating the date of the special read which will coincide with the proposed change date on the transfer request.
Jemena feedback Comments for Special Reads – In Situ, included in section 6 below Envestra feedback Envestra accept the proposal. Collective Retailers response to NWO feedback Refer to comments in ‘Special Reads – In Situ’
Where the CoU is a move-in, and there is no basic meter read within the past -10/+4 days and there is no scheduled read for the transfer day and the retailer has not requested a special read, the distributor will undertake a special meter reading on the proposed transfer day.
Jemena feedback Jemena currently provides a special meter read service that is contracted to be performed, and priced in such a way that is not compatible with the proposed timeframes and tight tolerances required to support the proposed requirement for an out of cycle read to be taken for in situ transfers. If the retailers require the network operator to provide a special read on a nominated date and within a specific timeframe, Jemena will be required to consider providing such a service under a separate commercial arrangement, and would in any case need to be considered for the next Access Arrangements for Jemena Gas Networks and for ActewAGL Distribution. Any such service would need to be priced based on the basis of the loss of the efficiency currently available to the distributor through utilising the diversity and scheduling flexibility available to the currently defined service. The viability of introducing any change requiring such a service should be considered carefully in order to ensure net benefit is achieved. Envestra feedback I’m assuming the prospective Retailer will be charged for any special reads that the DB is required to undertake for the Move In Transfers? Collective Retailers response to NWO feedback It is acknowledged Jemena provides a special meter read service. It is unclear as to why this would need to change in relation to in situ transfers where an appropriate notice period would apply to allow the distributor to obtain the special read. Issues concerning the cost for providing the special read service should be captured in the issues/risks register and addressed as part of the Access Arrangement.
Should there be no actual read available in the allowable period for the transfer, estimated as a result of no access, for example, AEMO will be advised and will issue a read failure notice to all impacted parties; New User, Current User and Distributor.
Jemena feedback Jemena notes that there is insufficient information in the paper on the use and impact of a read failure notice. Jemena seeks further information and guidance on the use and purpose of a read failure notice. Envestra feedback Can we please clarify that estimations are only provided where schedule reads were unable to be obtained due to no access and or Special Final Reads only? Collective Retailers response to NWO feedback In response to Envestra question; yes, estimations only apply where scheduled reads are unable to be obtained (generally due to no access) and a special read, final read cannot be obtained (again generally doe to no access). As indicated above, a Notice of Read Failure is generated by AEMO when no meter reads have been delivered to AEMO by the distributor with respect to the Change of User Request within the predetermined time interval. This notification allows the incoming retailer to take action e.g. provide AEMO with an alternative transfer date with AEMO subsequently notifying the distributor and the current retailer. Alternatively the incoming retailer can withdraw the transfer.
Where there is no access to read meters but meter data loggers (MDL) have been installed to provide reads, it is assumed the reads on the MDLs and the associated inaccessible meters coincide and as such the reads obtained from the meter data loggers can be used for transfer purposes. Jemena is to confirm this assumption is correct. Jemena feedback Jemena confirms that meter reads from meter data loggers are treated as actual meter reads in Jemena’s networks, should those reads pass the data validations processes. Envestra feedback This may be my understanding of the function of a Data Logger, but does this have an Actual read that you can transfer on, or is it just the consumption? Will this actually work? Collective Retailers response to NWO feedback In relation to Envestra’s questions it would appear from Jemena’s response data loggers do have reads but agree we would need to confirm using the read on the data logger for transfer purposes is appropriate.
By lodging a transfer request, the retailer is deemed to have requested the distributor to reconnect the site should the meter at the site of the transfer be plugged or turned off. If the transfer is subsequently cancelled, the distributor must reinstate the meter to be plugged or turned off. It is anticipated the process whereby any USER can apply for and receive accreditation by the network operator to perform disconnections and reconnections, will continue, unless there is a change to the relevant Federal/State legislation and Industry code.
Jemena feedback Jemena currently offers disconnection and reconnection services, and will continue to do so. However, Jemena will not reconnect a delivery point, if it is unsafe to do so, or contrary to its contractual or legislative obligations. Envestra feedback Where reconnection was completed and transfer is subsequently cancelled thus the site needs to be disconnected, does this mean that the retailer who cancelled the request is charged any associated costs for the connection/disconnection process being completed? Is the inclusion of the NSW Retail Market Procedures just for reference, as the last sentence contradicts the previous stated expectation that where a transfer is subsequently cancelled the DB must reinstate the meter to be plugged/or turned off? Collective Retailers response to NWO feedback It is understood reconnection will only be performed by the distributor where it is safe to do so and as permitted by contractual and legislative requirements. With respect to the costs for reconnection/disconnection; the retailer raising the transfer will be responsible for costs relating to connection and disconnection should the transfer be cancelled. Where the transfer has been cancelled prior to any field work being undertaken, the retailer will not incur any charges.
It is expected DPIs will continue to be transferred in error despite the introduction of B2B and B2M processes. To allow these DPIs to be ‘handed back’ to the correct retailer the current process, as it applies in NSW, will be adopted. The retailer will approach the distribution business who will provide details of the previous retailer. The retailer who has won the site in error will engage with the previous USER/FRO and arrange to raise an error correction transfer to ‘hand back’ the DPI to the previous USER/FRO.
Jemena feedback Jemena notes that the error correction processes that currently exist in the Retail Market Procedures (NSW & ACT) (Procedures) is a result of legacy arrangements prior to AEMO establishing its systems as the primary record of truth. Under the Procedures, AEMO is the record of truth when it comes to delivery point data. As such, AEMO is best placed to correct delivery point data and coordinate the correction of erroneous transactions. Care should be taken that given the exceptional and inherently manual nature of error corrections, that error corrections are limited to genuine errors, and not merely to correct undesirable commercial decisions. Allowing error corrections to be used to correct poor commercial decisions transfers risk and cost to participants who had no part in the poor decision. Similarly the benefit of a correction should be assessed against the cost of its implementation. To this end, general guidelines might be of assistance, including: 1. The error correction transactions should only be used to correct an error in the initial COU transaction raised by the retailer. 2. The retailer should only be permitted to raise a correction transaction, if the retailer has written consent for raising the correction transaction from the previous user. 3. Errors should only be corrected if they fall within allowable timeframes. Envestra feedback Recommended we adopt the SA model (Division 2.2.3 where Error Correction Notices) where if previous user is unknown to the current user (who transferred the site incorrectly) then the current user requests AEMO to notify the identity of the previous user so that a correction can be requested/approved/completed. It should be noted that the process for “won in error” is under review in the other states, and which ever process is agreed on for VIC, QLD and SA should then be retrofitted in to NSW (assuming NSW B2B proceeds). Collective Retailers response to NWO feedback The retailer’s view is for the error correction process to continue to operate as it currently does in NSW with the addition of AEMO providing the details of the previous User if they are unknown to the current User who transferred the DPI in error. Agree with Envestra’s response and suggest capturing the pending review as per the current Industry change register.
Retrospective transfers allow the retailer to ‘win’ the site as of a retrospective date when an actual reading is available. Retrospective transfers can be used in situations where:
All of the retrospective transfers would be subject to a permitted retrospective period. This would need to be agreed by market participants and AEMO.Refer to the example below from the Victorian RMP.
Jemena feedback Jemena does not support the introduction of a retrospective transfer process for the following reasons: • Accountability and responsibility is established, and exists at a particular point in time. Other than in cases of genuine error, responsibility for interaction conducted at a point in time on that understanding can not change retrospectively. COUTransactions should not be altered after the fact, i.e. via a retrospective transfer as this may cause distortions between market operator, user and network operator DPI databases and in participants’ contractual positions. • If a retailer implements a retrospective transfer, it is not clear which retailer would be accountable for the delivery point between the retrospective transfer date and the date that the retrospective transfer was initiated. • Jemena understands that the retrospective transfer process currently only applies in the Victorian and Queensland gas retail market and does not apply in the South Australian market. As such, Jemena believes that introducing this process in the NSW market is inconsistent with AEMO’s principle of harmonising the markets. • Jemena was advised that retailers only want the retrospective transfer process to apply in the NSW-Wilton network section. Jemena does not believe that it is appropriate for different transactions to apply to different network sections within a single jurisdiction. Envestra feedback As per the scoping document, retrospective transfers only apply in the STTM network sections. Collective Retailers response to NWO feedback As per the Envestra response; retrospective transfers will only apply in those network sections where the STTM is in place. If a retailer implements a retrospective transfer the retailer would be responsible for the delivery point from the date the transfer completes. It is expected the Gas Road Map for Vic, SA and QLD will be informed by the NSW B2B Project (and this paper), with opportunities of harmonisation identified. Conflict between the Road Map and the NSW B2B project is not anticipated
There is no objection for debt in NSW, however, the network has the ability to object to a transfer based on the retailer requesting the transfer not having a haulage agreement for the area in which the DPI is located or there is invalid data in the transfer request.
It is proposed to remove these objections and allow the market operator, AEMO, to undertake the validation of the transfer request, as it does inSA,QLD and Victoria. If there is invalid/incomplete data in the transfer request or the requesting retailer has no haulage agreement for the area in which the MIRN exists, then a negative acknowledgement will be sent. The negative acknowledgement will contain the relevant event code, severity and code description. Refer to the example below from Participants Build Pack 2 below. The distributor will need to ensure AEMO has an updated list of haulage areas and Retailers.
In order to accommodate retrospective transfers, the ability for the current USER to raise an objection of declined will be required. It is expected, as per section 11, agreement will need to be reached between the retailers for the transfer to proceed. Should the incoming USER not seek the agreement of the current USER, the current USER can raise an objection of ‘DECLINED’.The allowable window for an objection request,in the Victorian GIP, is bymidnight on the fifth business dayafter the day on which AEMOdelivered the transfer request notification to the FRO or the retrospectively affected FRO(as the case may be). Once an objection has been raised, it can move in various directions including; objection withdrawal, transfer withdrawal or a transfer cancellation due to expired objection.
Jemena feedback Jemena is responsible for maintaining the transportation agreement between the retailer and the distributor, for transportation of gas within its networks. As such, Jemena retains the right to object when the transactions raised in the market are not reflective of the transportation agreements, and will not delegate its contractual responsibilities to a third party (AEMO) to object on its behalf, if there is no transportation agreement in place between the network operator and the retailer. Envestra feedback Envestra accept the proposal. Collective Retailers response to NWO feedback The NSW/ACT Retail Market Procedures already allows for AEMO to validate CoU Move-in transactions. AEMO confirms the incoming User has a transportation agreement with the network operator for the transportation of gas to low consumption delivery points for the relevant network section to which the CoU DPI belongs. Refer to section 6.8 Assessment of User Change Data in the RMP. It is also expected, in the ‘future state’, AEMO would undertake this validation for in situ, low consumption delivery point transfers. Distributors will continue to validate CoU (move-in and in situ) transaction for ‘large’ sites (>1Tj) and provide an objection to AEMO to publish to the current and incoming FRO.
It is expected Problem Notices will continue to be used as outlined in Build Pack 2.
Jemena feedback Jemena requires further clarification on the use of Problem Notices. Information provided to date has not provided a sufficient understanding of which participants use this information and the extent it is used across industry. Envestra feedback Envestra accept the proposal. Collective Retailers response to NWO feedback Both AGL and Origin have provided information on the volumes and types of messages contained in the Problem Notice. Retailers continue to see the benefit in having the Problem Notice available for CoU in NSW/ACT to allow them to alert the incoming FRO of conditions at the site which may lead them to question if they want to proceed with the transfer. The transfer will progress unless the incoming FRO raises a withdrawal. If Jemena sees no value in the Problem Notice then they need not provide it. NSW Gas Change of User (CoU) Future State v2.0 120917 Page Yüklə 130,94 Kb. Dostları ilə paylaş:
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