Nsw gas Change of User Paper

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Title: NSW/ACT Gas Change of User (CoU) Future State

  1. Background


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.
  1. Actual Reads


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.
  1. In Situ CoU and Scheduled Reads


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
  1. 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.




SA Retail Market procedures v3.0
Division 4.2.4 – Basic meters – deemed meter readings

148. Deemed meter reading (basic meters only)

(1) If a meter reading for a basic-metered delivery point that generated an actual value was undertaken no more than 10 days before the date of move in, then(subject to clause 148(2)) on the date of move in:

(a) the network operator must determine a “deemed meter reading” which is a meter reading deemed to have occurred on the day of the move in; and

(b) provide the metering data from the deemed meter reading to AEMO.

(2) For the purposes of providing the metering data and calculating the energy value for a deemed meter reading, a network operator must use the most recent index reading from the meter reading which occurred no more than 10days before the move in to calculate the actual value under clause 155.





Vic Retail Market procedures v4.0
1.1.1 Definitions

The following words and phrases in these Procedures which appear in italics have the meaning given them in Part 19 of the Rules unless an intention to the contrary appears:



allowable period means either:

  1. (a) in relation to a transfer request notification lodged without a customer no-change statement, the period commencing on the 10th business day prior to the proposed transfer date and expiring on the fourth business day after the proposed transfer date; or

  2. (b) in relation to a transfer request notification lodged with a customer no-change statement, the period commencing on the fourth business day prior to the proposed transfer date and expiring on the fourth business day after the proposed transfer date.




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.
  1. Special Reads – In Situ


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.

SA Retail Market Procedures v3.0
Division 3.3.2 – The Transfer Request

81. Transfer request

(1) A transfer request must specify at least the following information:



    1. (a) the MIRN; and

    2. (b) the incoming user’s GBO identification; and

    3. (c) the earliest transfer day; and

{Note: Unless a special meter reading is requested for a basic-metered delivery point, the transfer of a basic-metered delivery point will take effect under clause 103(1)(c) at the time of the next scheduled meter reading which occurs on or after the earliest transfer day, provided an actual value is generated at that time.}

{Note: Under clause 83(i), an earliest transfer day must be no earlier than 5 business days after the date on which the transfer request is lodged (except where the requested transfer is a move in) and within the allowable period.}

{Note: For a move in, the transfer will take effect on the move in date or if there is no deemed meter reading or a special meter reading cannot be obtained on the move in date, it will take effect at the time a special meter reading is obtained under clause 99.}





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’

  1. Special Reads – Move-In


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.

SA Retail Market Procedures v3.0
99. Network operator may be required to undertake special meter reading

for a move in

(1) If a requested transfer is a move in and:

(a) the network operator determines as a reasonable and prudent person that there is no prospect of determining a deemed meter reading under clause 148(1)(a), for the earliest transfer day; and

{Note: The network operator may make this determination if it determines that there is unlikely to be a validated scheduled meter reading or special meter reading in the 10 days before the move in.}

(b) no scheduled meter reading is scheduled for the earliest transfer day; and

(c) no special meter reading has been requested (at least 2 business days prior to the earliest transfer day) by the user, for the earliest transfer day,

{Note: If a user requests a special meter reading for the earliest transfer day and cancels the request less than 2 business days prior to the earliest transfer day, the networkoperator will not be able to undertake a special meterreading on the earliest transfer day, because under clause

147(1), the network operator requires at least 2 business days noticein order to undertake a special meter reading.}then, the network operator must undertake a special meter reading:

(d) on the earliest transfer day; or

(e) if the earliest transfer day is less than 2 business days after AEMO gives notice under clause 98(d) that the transfer is pending ― within 2 business days after receipt of the notice.

(2) If a requested transfer is a move in and either:


    1. (a) a scheduled meter reading is scheduled for, or not more than 10 days before, the earliest transfer day; or

    2. (b) a special meter reading has been requested (at least 2 business days prior to the earliest transfer day) for, or not more than 10 days before, the earliesttransfer day by either:

    3. (i) the current user; or

    4. (ii) the incoming user; or

    5. (c) the network operator is required to undertake a special meter reading under clause 99(1)(d) or 99(1)(e);

and the network operator fails to obtain a meter reading under at least one of clauses 99(2)(a), 99(2)(b)(i), 99(2)(b)(ii) or 99(2)(c), then the network operator must promptly notify the incoming user of the failure.

(3) If within 3 business days after notifying the incoming user under clause 99(2) the network operator receives a request from the incoming user to undertake a special meter reading, the network operator must undertake as soon as practicable a special meter reading for the delivery point the subject of the requested transfer clause 99(1).

(4) If AEMO does not receive metering data under clause 158 that contains an actual value or a substituted value within 7 business days of the earliest transfer day, then AEMO must:



    1. (a) forthwith cancel the requested transfer; and

    2. (b) immediately notify the incoming user, the current user and the network operator that the requested transfer has been cancelled.


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.
  1. No Actual Read Available


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.

SA Retail Market procedures v3.0
Division 3.3.7 – Actual Value Required For Requested Transfer Of a Basic Metered Delivery Point

101. Requested transfer of a basic-metered delivery point requires meter reading that has generated an actual value

(1) If a requested transfer for a basic-metered delivery point is pending and AEMO receives metering data under clause 158 that contains an estimated value, AEMO must within 24 hours notify the incoming user and current user that the requested transfer cannot take place until AEMO receives an actual value for the delivery point.

{Note: The network operator may provide AEMO with metering data that contains an actual value for the delivery point at any time. However, if meter reading that generates an actual value is takenafter the allowable period has elapsed, AEMO will have already cancelled the requested transfer.}

{Note: Clause 81(2) provides that a requested transfer may be specified to be a move in.}

(2) If a requested transfer for a basic-metered delivery point is pending and AEMO does not receive notification of an actual value for the delivery point within the allowable period, then within 24 hours of the lapse of allowable period AEMO must:


    1. (a) cancel the requested transfer; and

    2. (b) notifythe incoming user, the current user and the network operator that the requested transfer is cancelled.

{Note: An incoming user wishing to reinitiate a requested transfer that has been cancelled must lodge a new transfer request.}





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.
  1. Data Loggers


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.
  1. Reconnection Associated with CoU


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.


SA Retail Market Procedures v3.0
Division 3.3.2 – The Transfer Request

82. Transfer request deemed to be a request for certain purposes

By lodging a transfer request, the incoming user is deemed to have requested the network operator, as part of the transfer process:

(a) if a basic-metered delivery point is decommissioned — to reconnect it; and

(b) if the requested transfer is cancelled after a reconnection has occurred under clause 117(1)(c) — to disconnect it again; and

(c) if the requested transfer is a move in at a basic-metered delivery point — to undertake a special meter reading under clause 99(1).





NSW Retail Market Procedures v4.0
6.8 Assessment of user change data and meter reconnection

(5) If the change of user transaction is a move-in and the relevant network operator is aware that the delivery point is disconnected then when it receives the notice under clause 6.8(3)(b) the network operator:

(a) will be deemed to have received a request from the current user on behalf of the incoming user to reconnect the delivery point; and

(b) subject to clause 6.8(6), must reconnect the delivery point on or as soon as reasonably practicable after the date notified under clause 6.8(3)(b)(vii).

(6) The network operator is not required to comply with clause 6.8(5)(b) if it is aware that the relevant delivery point was disconnected for safety-related reasons.

(7) If the registry operator subsequently notifies a network operator that a change of user transaction has been cancelled or reversed:

(a) the request to reconnect the gas supply that was deemed to have been received from the current user under clause 6.8(5)(a) will be deemed to be withdrawn with effect from the date that the network operator received the notification; and

(b) If the network operator receives the notification after it has reconnected the gas supply at the relevant delivery point the network operator must notify the current user of the reconnection.





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.
  1. Error Corrections


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.



NSW Retail Market procedures v4.0
11.1 Current user may initiate a correction to delivery point information

(3) A current user must not initiate a correction transaction under clause 11.1(2) in relation to a change of user transaction if:

(a) the previous user is not a market participant or is a removed user;

(b) the customer at the relevant delivery point immediately prior to the initiation of the correction transaction is not the customer that was at the delivery point immediately prior to the initiation of the relevant transaction, unless the current user has agreed with the previous user compensation for the costs that would be incurred by the previous user if the correction transaction was completed;

(c) the current user has not obtained the previous user’s consent in writing to initiate the correction transaction; or

(d) that transaction relates to a delivery point for which:

(i) a retailer of last resort is recorded in the delivery point registry; and

(ii) theprevious user of the delivery point is an affected user.

(4) A previous user:

(a) must consent to the initiation of a correction transaction in relation to a change of user transaction if there was an error in some or all of the information provided by a user when it initiated the relevant transaction, unless:

(i) the customer at the relevant delivery point at the time the correction transaction will be initiated was not the customer at the delivery point immediately prior to the initiation of the relevant transaction and the current user has not agreed with the previous user compensation for the costs that would be incurred by the previous user if the correction transaction was completed; or

(ii) theprevious user’s consent was sought more than 15 business days after the relevant transaction was completed under clause 6.17 and the current user has not agreed with the previous user compensation for the costs that would be incurred by the previous user if the correction transaction was completed.





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.
  1. Retrospective Transfers


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:

  • the customer has moved into the site and a retrospective read is available (this reading and date will be provided in the MRN discovery response)

  • the transfer date was missed due to an internal error and there is agreement between the prospective and current FRO to transfer the customer on the retrospective date

  • there is agreement between the prospective and current FRO to transfer the DPI based on a previous actual meter read.

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.

Vic Retail Market Procedures v4.0
4.1.3 Retrospective Transfers

A Market Participant must not deliver a transfer request in relation to a supply point to AEMO where the proposed transfer date in relation to that transfer request is a retrospective transfer date unless:



  1. (a) that Market Participant:

  2. (i) is a Market Participant as at the day on which the transfer request is delivered to AEMO; and

  3. (ii) was a Market Participant at all such times during the permitted retrospective period for the transfer request when, if that person were to be registered in the metering register as the FRO for the supply point with effect from the retrospective transfer date to the registration end date (if any), it would have been the FRO for that supply point; and

  4. (b) theretrospectively affected FRO in relation to that transfer request is a Market Participant as at the day on which the transfer request is delivered to AEMO.

permitted retrospective period, in relation to a transfer request, means the period of 118 business days expiring immediately before the day on which the transfer request is delivered to AEMO.


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

  1. Objections to Transfers


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.

NSW Retail market procedures v9.0
6.13 Registry operator to ascertain whether there are any objections to change of user transaction
(4) The relevant network operator may object to a change of user transaction on

one or more of the following grounds:

(a) that some or all of the user change data is incorrect; and/or

(b) transportation agreements required under an access arrangement are

not in place.

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.

Vic Participant Build Pack 2 v3.0

Appendix C. Gas FRC Application Event Codes

CODE DESCRIPTION SEVERITY INVOKING TRANSACTION

3045 Participant has no Error CATSChangeRequest

rights inthe Network

3020 The change reason Error CATSChangeRequest

cannot be found

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.

Vic Participant Build Pack 2 v3.0

Appendix A. Data Dictionary

A.1 aseXML Data Elements1
ObjectionCode Objection Reason Code Identifies the reason for an objection to a transfer. String 8“DECLINED” = Retrospectively Affected FRO does not consent to transfer




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.

  1. Problem Notices


It is expected Problem Notices will continue to be used as outlined in Build Pack 2.

Vic Participant Build Pack 2 v3.0

4.1.11 Delivering Problem Notice

The Problem Notice described in this section is responsible for conveying change information to the Market Participant (New FRO) who initiated the Change Request. The sender of the Problem Notice may include whatever text they like in the Event associated with the notice and AEMO will pass the Event unaltered to the New FRO.

There are two triggers that result in a Problem Notice being initiated. They are

1. the Current FRO or Distributor initiating a Problem Notice (CATSChangeAlert);

2. as a result of receiving a NegativeAcknowledgment (NAK) to a CATSNotification transaction, containing specific event codes, from either the Current FRO or Distributor, AEMO will generate a Problems Notice (CATSChangeAlert) to the New FRO.

Only NAK’s that contains Event Codes that are listed in appendix C in the CATS

category range or Event Codes, 3200, 3202, 202 or –1 will result in the generation of a Problem Notice. The reason AEMO issues a Problem Notice on receipt of a NAK

generated against a CATSNotification is it is the only mechanism available to a Current FRO and Distributor such that it can provide feedback about a problem to the New FRO without knowing the identity of the New FRO. Confidentiality rules that apply in the market prevent AEMO from identifying the New FRO to the Current FRO.



It should also be noted that the existence of a Problem Notice does not impact, in any way, the CATS processing Procedures associated with a transfer. It is up to the New FRO to evaluate the impact of the information provided in the Problem Notice and takes whatever steps are appropriate. These steps can range from withdrawing the transfer to ignoring the Problem Notice.


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



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