Customer Functions Service Provider Role Paper

Transcription

1 Background Customer Functions Service Provider Role Paper One of the General Policy Principles in all jurisdictions for small customers was to ensure that all parties who provide access to enable provision of customer services functions must do soon the basis of competitive neutrality. The National Stakeholder Steering Committee Released the NSMP Access and Contestability Principles in May 2010 (Annexed to this document). In this paper, the NSSC agreed the requirement for the introduction of a new Customer Functions Service Provider, who is appointed by the Responsible Person, and will be accredited by the Australian Energy Market Operator (AEMO) The NSSC also agreed that the Customer Functions Service Provider need to provide open access to the defined functions and therefore, to ensure competitive neutrality, it needs to be established as a separate body contracted by the party that manages metering on behalf of the customer. This new role means that there will be three distinct providers in the metering space: The Meter Provider (MP, who provides the meter installation and communication facilities; The Meter Data Provider (MDP) 1 accesses the meter data and makes it available to AEMO, the LNSP and the FRMP. The MDP can also provide the data to other parties with the agreement of or at the direction of the Customer The Customer Functions Service Provider (CFSP), who will provide access to the customer functions of a smart meter. Smart Metering Vision 1. The National Stakeholder Steering Committee s (NSSC) mandate from the Ministerial Council on Energy (MCE) is to: a) Develop and recommend technical specifications, performance requirements and amendments to functions, based on a sound benefits case; b) Develop and recommend standards, including analysis of cost implications; c) Propose supporting NER changes; d) Develop appropriate supporting technical documentation through standards and/ or National Electricity Market (NEM) procedures; e) Consider any related decisions arising from Phase 2 of the cost-benefit assessment. 2. The objective is to enable consumers to make more informed choices and better manage their electricity use and greenhouse gas emissions. This vision acknowledges that: a) the technology and cost for providing customer load management products and other functions to consumers will undergo rapid change over the expected life of smart metering infrastructure (15 years) including communications (7 years); and b) smart meters will be only one of several mechanisms available to consumers in a competitive market for customer services. The NSSC considers that the regulatory framework for smart metering should be simple and flexible, consistent with the NEL Objective, and not constrain competition in the delivery of customer services, technology innovation, or customer choice. 2 1 Currently the Rules refer to a Meter Data Agent (MDA). It is proposed that this role be defined in the Rules as a Meter Data Provider (MDP). This paper will refer to the role as MDP. 1

2 Management of Metering in the NEM The management of meters in the NEM is charged to the Responsible Person. As per clause of the National Electricity Rules the Responsible Person is the person responsible for the provision, installation and maintenance of a metering installation in accordance with: (1) chapter 7; and (2) the metrology procedure. A Market Participant may elect to be the Responsible Person for a metering installation that is a type 1, 2, 3 or 4 metering installation3 or a Market Participant may request in writing an offer from the Local Network Service Provider to act as the Responsible Person. Most retailers currently choose to be the Responsible Person for Type 1, 2, 3 or 4 metering installations. Currently, Clause 7.2 provides for the LNSP to be the Responsible Person for Type 5, 6 and 7 meters. The Responsible Person is required to: Engage a Metering Provider. A Metering Provider is responsible for providing and maintaining the security controls of a metering installation 4. They are required to physically provide a meter and any related equipment (including communications) to allow the meter to operate. Installation and maintenance of metering installations must only be carried out by a Metering Provider. 5 The Metering Provider is a defined role within the NEM and under the existing arrangements any person may apply to AEMO for accreditation and registration as a Metering Provider, and provide this service on a contestable basis to the Responsible Person. Where the LNSP is the Responsible Person role under the Rules, then the general practice is that the Metering Provider is affiliated with the LNSP. Engage a Meter Data Provider. A Meter Data Provider arranges for the collection and transmission of the meter data to the customers energy retailer, Australian Energy Market Operator (AEMO) and the distributor. The recent introduction of the Smart Meter legislation (National Electricity Law Amendment (Smart Meter Bill), means that a jurisdictional Minister may, for the specific time period, mandate the roll-out of smart meter for a specific category of small customers on an exclusive basis for. During the mandate period, the LNSP is appointed the Responsible Person and required to fulfil those responsibilities and, in return, the LNSP receives a regulated rate of return to recover the capital and operating costs of the mandated roll-out (as approved by the AER). The MCE specifically provided for the provision of meters and the related data services: As a critical part of the national framework, MCE agrees that distributors are the most appropriate party to manage any obligation for an accelerated roll-out. To support this MCE agrees that residential and small customer metering and related data management services should remain the responsibility of distributors in NEM jurisdictions for at least the roll-out period. This decision is consistent with the current approach in Victoria. To provide clarity on this policy position, and to allow the AEMC to consider any related Rule changes efficiently, MCE will release a Statement of Policy Principles on this matter. Smart Meter Decision Paper, MCE 13 June 2008 This decision is not clear on a number of matters, relevantly, the customer services functions and what assessments need to be made at the end of the accelerated roll-out. For example, at this stage, the LNSP s regulated role as the RP for a smart meter roll-out concludes at the end of the mandated period. The NSSC is therefore explicitly tasked to provide advice on the 2 NSMP access and contestability principles v10 May doc 3 National Electricity Rules Clause National Electricity Rules Clause National Electricity Rules Clause 7.4 2

3 transitional rules and other matters associated with both the accelerated roll-out, the transition to the normal market and adoption of smart meters outside of the mandate framework. The NSSC has made two critical decisions that require changes to the Rules; the requirement for a gateway review, to ensure appropriate arrangements are put in place for the return to contestable metering, and the new role of Customer Functions Service Provider, to ensure open access to those defined functions. Smart Metering The MCE Smart meter functions include 6 : Energy measurement functions (1-7, 9, 10, 11) Meter maintenance functions- (now remote in addition to local) F25 Remote reconfiguration F 26 Remote software upgrade F29 Plug and play device commissioning (e.g. meters) New Customer Service functions Load management (switching functions) F8/14 Load management F12 Remote connect/disconnect F13 Supply capacity control F16 HAN interface (load mgt via the HAN) Quality of Supply functions (data capture) F 19 Quality of supply and other event recording F20 Meter loss of supply detection and outage detection The energy measurement and storage functions are not new and are currently available on Type 4 remotely read meters although not all maintenance functions may be capable of remote enablement. Smart metering however introduces additional meter functions not considered traditional Energy Measurement/ Metrology functions. These might be provided by either the Meter Provider or the Meter Data Provider under the existing role obligations. As a result this limitation requires a clear separation of the smart meter functions into two categories: 1. Energy measurement/ Metrology functions; and 2. Customer service functions The Metrology Functions include the following and are provided by either the MP or the MDP based on the existing role obligations in the rules: Function # Function #7.1 Functions #7.2 Function #7.3 Function #7.4 Function #7.5 Functions #7.8 Function Description Measurement and Recording Remote Acquisition Local Acquisition Visual display and indicators on meter Meter Clock Synchronisation Distribution Network Import Supply Capacity Limit/ Emergency 6 National Stakeholder Steering Committee Policy Issues Consultation 3

4 Function # Function #7.10 Function #7.13 Function #7.14 Function #7.15 Function #7.16 Function #7.17 Function Description Quality of supply & other Event Recording Meter Settings Reconfiguration Software upgrades Plug & Play Device commissioning Communications and Data Security Tamper Detection The customer service functions include the following: Function # Function #7.6 Function #7.7 Functions #7.8 Function #7.9 Function #7.10 Function #7.12 Function #7.13 Function #7.14 Function Description Load management through a controlled load contactor Supply Contactor operation Time of Day Import Supply Capacity Limit HAN using Open Standard Quality of Supply and other Event Recording Remote Service Checking Meter Settings Reconfiguration Software upgrades Roles and Responsibilities Customer Functions Service Provider The NSSC has agreed, in the NSMP access and contestability policy principles, the requirement for the introduction of a new Customer Functions Service Provider, who is appointed by the Responsible Person, and will be accredited by the Australian Energy Market Operator (AEMO) to manage the operation of the additional meter functions of the smart meter. This role, the Customer Functions Service Provider would provide the necessary communications and back-office functions to allow a party to access the additional smart functions. The addition of the new role requires the NSSC to clearly define and delineate the roles of MP, MDP and CFSP in the NEM, noting that the roles may be performed by different parties over time and facilitates the MCE expectation: As a critical part of the national framework, MCE agrees that distributors are the most appropriate party to manage any obligation for an accelerated roll-out. To support this MCE agrees that residential and small customer metering and related data management services should remain the responsibility of distributors in NEM jurisdictions for at least the roll-out period. This decision is consistent with the current approach in Victoria. To provide clarity on this policy position, and to allow the AEMC to consider any related Rule changes efficiently, MCE will release a Statement of Policy Principles on this matter. Smart Meter Decision Paper, MCE 13 June 2008 "MCE remains open to further expansion of contestable metering beyond the roll-out period and as technology and retail competition matures to support this. Regulatory and operational arrangements in the national framework should be designed with future flexibility on this matter in mind" 7 7 Smart Meter Decision Paper MCE 13 June 2008 p7 4

5 This approach seeks to maximise the potential for meter competition and contestability in service provision, whether it is post a mandated roll-out or for non-mandated rollout. It does not, however, deal to the operation of the customer services functions. The lack of clarity, which is considered deliberate, allows the NSSC some scope in how it would define these roles to and assist industry in the transition from mandate to post-mandate operation. This paper therefore considers a number of options that would allow the MCE to achieve its stated intentions and compares them with the objectives the NSSC established in the Access and Policy Principles Paper. The options are further explained in terms of engagement approaches in Attachment 1. Nomination of the roles & responsibilities Within the Rules the MP, MDP and CFSP will be obliged to provide their defined services to the LNSP, FRMP and AEMO. The key question is how these should be managed. The introduction of smart meters allows for the provision of the two very distinct services, metrology and non-metrology services, with the MP and MDP providing metrology services and the CFSP providing non-metrology services. Under existing arrangements 8 model of, the Responsible Person is required to appoint MP and MDP s for the provision of metrology services. The metrology services are largely for the provision of infrastructure, reading meter data and metering maintenance. The RP role is actually a convenient shorthand for either the FRMP or the LNSP, since the role is performed by staff from these organisations. The MP and MDP are currently separately identified parties, although almost always associated with LNSPs. The current Rule proposal, and the additional role proposed by the NSSC allows 9 us to propose changes to the RP role to meet the NSSC desire that the regulatory framework for smart metering should be simple and flexible, consistent with the NEL Objective, and not constrain competition in the delivery of customer services, technology innovation, or customer choice. 10 The issue is how the three functions contribute to the mandated roll-out, impact on NSP cost recovery, influence ongoing functionality and enhance the National Electricity Objective 11. IN addition the combinations and management of these functions need to be considered against the NSSC criteria; simplicity, flexibility, consistency with the NEL Objective and no constraints on competition in the delivery of customer services, technology innovation, or customer choice. Note on the Victorian arrangements The current meter roll-out in Victoria have been established under a different arrangement. While in the long run these need to be brought into the national scheme, this is currently not required, and the Victorian Government has explicitly excluded Victoria from the NSMP Rule changes. The Victorian arrangements are described in Appendix 2 to this paper. In the longer term, Victoria will need to establish how it can provide a contestable metering framework to prevent the loss of benefits from its accelerated roll-out. A more flexible national scheme should support any arrangements established by Victoria. 8 This is currently under review by the AEMC. At market start the Responsible Person was either the FRMP or the LNSP if chosen by the FRMP. During changes to the Rules to accommodate full retail contestability and also the rollout of type 5 meters, this was changed and for locally read meters, the responsible person was allocated to the LNSP. The AEMC are currently reviewing changes for remotely read meters that will reinstate the clear role of the Responsible Person. 9 It is actually a requirement that the NSSC propose Rule changes, such as that to provide for the gateway review, to refine the approach of the MCE to mandated roll-outs of smart meters. 10 NSMP access and contestability principles v10 May doc 11 The AEMC have explicitly stated that their assessment of any Rule change proposal will be against the National Electricity Objective, not the NSSC nor MCE preferences. 5

6 The functions The three functions to be performed in the market are: The Meter Provider. The Meter Provider is the party responsible for provision of the meter and associated infrastructure (which included communications). This is the key role performed by the LNSP in the accelerated rollout of smart meters and therefore this is a function to be allocated to the LNSP during mandates for both efficiency and cost recovery reasons. Most, if not all, Meter Providers are associated with LNSPs; The Meter Data Provider. The Meter Data Provider is responsible for the collection of usage data from meters and providing to AEMO, the LNSP and the FRMP. This includes necessary data transformations. This role is not integral to the mandated rollout but, like the Meter Provider, most Meter Data Providers are associated with LNSPs; The Customer Functions Service Provider. This has been defined above and covers the key functions that provide a benefit to customers and form part of the contract between retailers and their customers. This is not integral to an accelerated roll-out and the NSSC have agreed that this function needs to be performed in a manner that promotes open access on an equal basis for all parties. The Proposed options There are three options that have been identified as potential engagement models of the roles and responsibilities to ensure that the NSSC access and contestability principles are achieved: Option 1- The Responsible Person is the LNSP for the mandate period and all of the functions are appointed by the Responsible Person; Option 2- The FRMP is the Responsible Person at all times but during the mandate period, is required to use the LNSPs Meter Provider and (optional) Meter Data Provider. The Responsible Person appoints the Customer Functions Service Provider; and Option 3- The role of Responsible Person is abolished and the FRMP directly appoints all service provider roles. During the mandate period, the FRMP is required to use the LNSP as the Meter Provider and (optional) the Meter Data Provider. The FRMP appoints the Customer Functions Service Provider. Option 1. Responsible Person appoints all roles The Responsible Person is defined by the transitional rule as the party that has the exclusivity to appoint all Service Provider roles (MP, MDP and CFSP) during a mandated period. In this option the Responsible Person during the mandate, which is the LNSP, would be responsible to appoint all three Service Providers- the MP, MDP and the CFSP. Post the mandate the FRMP would be acting as the Responsible Person and the LNSP would have to put forward an offer to the FRMP similar to existing rules for types 1 to 4 metering. The CSFP would be an accredited role by AEMO. Metrology Services Responsible Person Roles Responsibility Mandate Post-mandate Non-mandate MP Meter, device and comms interface LNSP FRMP FRMP MDP Energy Measurement Services LNSP FRMP FRMP 6

7 Non-Metrology Services Nominated by Roles Responsibility Mandate Post-mandate Non-mandate CFSP Customer service functions LNSP FRMP FRMP Analysis against the criteria: Simple and flexible Consistent with the NEL Objective Supports competition in the delivery of customer services Supports technology innovation Supports customer choice Simple but not flexible. Post mandate the roles cannot be easily split, say to continue the LNSP as the MP independently of the other functions. Consistent Does not easily provide for competition Supports, although it could be argued that competition supports this more Does not support customer choice. Option 2. FRMP directly appoints the Non Metrology Service Provider (CFSP) In this option, the FRMP will act as the Responsible person. The Rule establishing the mandate for the accelerated roll-out will require that the LNSP acts as the MP and MDP. The FRMP will appoint the CFSP and is a contestable role during the mandate and post mandate. This is consistent with the MCE Policy Statement and post mandate the FRMP is the Responsible Person which is consistent with the NSSC Access and contestability principles where contestability in the service provision occurs post a mandated period. Metrology Services Roles Responsibility Mandate Post-mandate Non-mandate MP Meter, device and comms interface LNSP FRMP FRMP MDP Energy Measurement Services LNSP FRMP FRMP Non-Metrology Services Nominated by Roles Responsibility Mandate Post-mandate Non-mandate CFSP Customer service functions FRMP FRMP FRMP Analysis against the criteria: Simple and flexible Consistent with the NEL Objective Supports competition in the delivery of customer services Supports technology innovation Supports customer choice Flexible. Post mandate the roles can be easily split, say to continue the LNSP as the MP independently of the other functions. Consistent Provides for competition Supports Supports 7

8 Option 3. The FRMP is responsible for metering but must use the LNSP during mandates FRMP directly appoints all service provider roles- the MP, MDP and the CFSP. However, during the mandate, the MCE transitional rule will provision for the LNSP to appoint the MP and MDP for the purposes of a mass rollout of smart metering infrastructure. In this scenario, the Responsible Person role would be replaced by the FRMP, who is responsible for the end to end requirements for metering at a connection point Metrology Services Direct appointment arrangements Roles Responsibility Mandate Post-mandate Non-mandate MP Meter, device and comms interface LNSP FRMP FRMP MDP Energy Measurement Services LNSP FRMP FRMP Non-Metrology Services Nominated by Roles Responsibility Mandate Post-mandate Non-mandate CFSP Customer service functions FRMP FRMP FRMP Analysis against the criteria: Simple and flexible Consistent with the NEL Objective Supports competition in the delivery of customer services Supports technology innovation Supports customer choice Flexible. Post mandate the roles can be easily split, say to continue the LNSP as the MP independently of the other functions. Consistent Provides for competition Supports Supports The ERAA view The ERAA reasons for the nomination of the CFSP by the FRMP under a mandate, postmandate and in a non-mandate are: Mandate and post-mandate Non-mandate Retailer access and use of non-metrology services should be competitive, even during a mandate. This approach encourages a customer-centric focus on non-metrology SMI services. It also provides incentives for LNSPs (where they offer a CFSP role to retailers) to make competitive offers to retailers. Having the nomination of the CFSP default to the LNSP during a mandate period does not create this competitive environment. Since many of the retailer provided CFSP nonmetrology functions are taken up by customers on an opt-in basis, the price of CFSP services can be unregulated (as MP and MDA/MDP services are today) under a mandate. Under a non-mandate situation, SMI is deployed on a commercial basis and will be a type 4 or above meter type. On that basis no rule changes will be required as the FRMP will be the RP and may assign the RP role and the functions that might be provided by a CFSP in a formal mandate situation to the LNSP (in accordance with current chapter 7 provisions). 8

9 Risk of not adopting proposed any of the proposed options: The MCE will need to consider that if one or the other of the suggested infrastructure arrangements are not adopted, the national framework will result in a similar situation as Victoria 12 where proprietary communication systems have been installed and open access to the smart metering infrastructure will be more difficult. Since the current Rules assume contestability for remotely read meters and all associated functions, and the concepts for accelerated roll-outs also assume a return to contestable provision, the Rules need to provide a scheme that maximise the ability for jurisdictions to retain their flexibility in how the mandates are made to minimise the overall costs. The Rules proposed by the NSSC also need to support the achievement of the National Electricity Objective and therefore ensure the best long term outcome. It is therefore important that the proposed Rules assume contestability and choice in the longer term and minimising all costs, end-to-end in the metering space for the long term benefit of consumers. The NSSC Conclusion To be written by Harry after our next meeting 12 See attachment 2 9

10 Blank for DS printing. 10

11 Attachment 1: Engagement Arrangements for the Options The options in the paper can be further explained according to the set of engagement arrangements. Option #1: Responsible Person appoints all roles Direct access for provision of Metrology & Non Metrology Services during Mandate: The Responsible Person is defined by the transitional rule as the party that has the exclusivity to appoint all Service Provider roles (MP, MDP and CFSP) during a mandated period. In this option the Responsible Person during the mandate, which is the LNSP, would be responsible to appoint all three Service Providers- the MP, MDP and the CFSP. Figure 1 Option 1 during mandate via transitional rule In this scenario, there are a number of assumptions: The LNSP is the Responsible Person nominating the MP, MDP and CFSP during the mandate period only and via a transitional rule to the default arrangements Default arrangements for existing type 1-4 metering apply post mandate and in non mandate All three roles appointed by the LNSP must be on a competitive neutrality basis with ring fencing arrangements The MP is responsible for installation and maintenance of the smart meter (Meter Management) and smart meter communications network. The CFSP is responsible for the provision of the smart metering Non Metrology functions The MDP will be responsible for acquisition of metering data from the smart meter and for making it available to AEMO, the LNSP, and FRMP and any other party authorised by the Customer. The CFSP will provide access to the customer service functions of a smart meter. The MDP will provide direct access to allow the CFSP to directly communicate with smart meters. (For example, the MDP uses MV 90 to communicate with a meter via the public telecommunications network while the CFSP installs their own application software to communicate with the smart meter) Consistent with the SMI F.S. the smart meter installed by the MP will have full hardware and application (Function 23 & 24) interoperability in the smart metering infrastructure in order to work and allow for contestability in the service provision post mandate and minimise long term costs on consumers To ensure transition to contestability and competitive neutrality, two service providers will communicate with the smart meters (e.g. MDP and CFSP) and there will be protocols to regulate communications access to smart meters.. 11

12 The paper assumes that the CFSP is an accredited role by AEMO under the rules and operates outside of the Chapter 7 Responsible Person framework. The FRMP will have a contractual relationship with the LNSP as the Responsible Person who will have rules obligations to ensure service levels are met under monopoly arrangements during the mandate. CFSP contract/ rules obligations to the Responsible Person must include priority access conditions to meter control for the customer service functions. Emergency management protocols will need to be developed to cover access during emergency/network Security periods. (Definition for network security is required) The CFSP will need to support the continuation of existing LNSP load management functions such as controlled hot water load/ ripple control. The introduction of new consumer centric load management functions (such as interruptible air conditioning) would be supported by the CFSP in accordance with load management protocols and guidelines which are yet to be developed. In the Phase 1 NERA report they state: Interoperability for meters / devices at application layer allows requests and messages to be sent to the smart metering system by parties other than the party primarily responsible through a standard interface (e.g. MV90- type solution). This is achieved through having a standardised application layer utilising known device driver protocols. A common application layer allows one network management system to communicate with multiple smart metering systems. This ensures that the smart meter system operator is not locked into a separate proprietary network management system for each smart meter system. This has the potential to facilitate competition between manufacturers of network management systems. Interoperability at the application layer may also allow parties other than the meter owner or smart meter operator to access data from the smart meter. This may result in improvements in the customer transfer process. Also, quoting from the interoperability paper 13 produced by Martin Gill which states that, It is acknowledged that there may be issues associated multiple parties attempting to control a meter. These issues relate to the control of functions and can be solved by coordinating access, so that only one party can control functionality, or only supporting read access to the meter (such as to acquire the meter s energy data 14.) The statements above strongly suggest that multiple parties can control various functions of the smart meter via a coordinated open access available through function 23 (i.e. the application layer of the OSI model on which the SM infrastructure is based on) and therefore, the suggested arrangement is feasible. Consistent with the SMI F.S., open access will allow for contestability of the provision of nonmetrology (CFSP) services even during mandate and enable full-contestability in the Metrology and Non-metrology services provision post mandate. 13 NSMP Interoperability Meter Protocols v0.1.doc 14 Chapter 7 of the National Electricity Rules already provides that a FRMP and Distributor can both have read access to acquire data from a remotely read interval meter. 12

13 Option # 1: Responsible Person appoints all roles Direct access for provision of Metrology & Non Metrology Services Post Mandate: Post the mandate, the FRMP is the Responsible Person for both the Metrology and NonMetrology Services appointing the MP, MDP and CFSP.. In this arrangement, the LNSP would have to put forward an offer to the FRMP similar to existing rules for types 1 to 4 metering. The CSFP would be an accredited role by AEMO. Figure 2 Option 1 default arrangements (post mandate) In this option, there are a number of assumptions: The FRMP is the Responsible Person for the provision of Metrology and Non- Metrology Services The MP is responsible for installation and maintenance of the smart meter. The MP is responsible for installation and maintenance of the smart meter (Meter Management) and smart meter communications network. The CFSP is responsible for the provision of the smart metering Non Metrology functions The MDP will be responsible for acquisition of metering data from the smart meter and for making it available to AEMO, the LNSP, and FRMP and any other party authorised by the Customer. The CFSP will provide access to the customer service functions of a smart meter. The MDP will provide direct access to allow the CFSP to directly communicate with smart meters. (For example, the MDP uses MV 90 to communicate with a meter via the public telecommunications network while the CFSP installs their own application software to communicate with the smart meter) Consistent with the SMI F.S. the smart meter installed by the MP will have full hardware and application (Function 23 & 24) interoperability in the smart metering infrastructure in order to work. Two service providers will communicate with the smart meters (e.g. MDP and CFSP) and there will be protocols to regulate communications access to smart meters The paper assumes that the CFSP is an accredited role by AEMO under the rules and operates outside of the Chapter 7 Responsible Person framework. The FRMP will have a contractual relationship with the CFSP and the CFSP will have rules obligations to ensure network security. CFSP contract/ rules obligations to the FRMP must include priority access conditions to meter control for the customer service functions. Emergency management protocols will need to be developed to cover access during emergency/network Security periods. (Definition for network security is required) The CFSP will need to support the continuation of existing LNSP load management functions such as controlled hot water load/ ripple control. The introduction of new consumer centric load management functions (such as interruptible air conditioning) would be supported by the CFSP in accordance with load management protocols and guidelines which are yet to be developed. 13

14 Option #2: FRMP is the Responsible Person but must use the LNSP for the MP and MDP during mandates. FRMP directly appoints the CFSP Direct access for provision of Metrology & Non Metrology Services during Mandate: In this option, the FRMP directly appoints the CFSP during a mandate and post mandate. The CFSP is provided secure access to the existing communications network to carry out the nonmetrology services from the smart meter. The LNSP will appoint the MP and the MDP and ensure that secure access is provided to the CFSP to carry out their service provider obligations under the rules to the FRMP, LNSP and AEMO. Figure 3 Option 2 during mandate via a transitional rule for the LNSP to act as RP In this scenario, there are a number of assumptions: The LNSP nominates the MP and MDP for the exclusive period of the mandate The FRMP directly nominates the CFSP Default arrangements for existing type 1-4 metering apply post mandate and in non mandate All roles appointed by the LNSP must be on a competitive neutrality basis with ring fencing arrangements The MP is responsible for installation and maintenance of the smart meter. The MP is responsible for installation and maintenance of the smart meter (Meter Management) and smart meter communications network. The CFSP is responsible for the provision of the smart metering Non Metrology functions The MDP will be responsible for acquisition of metering data from the smart meter and for making it available to AEMO, the LNSP, and FRMP and any other party authorised by the Customer. The CFSP will provide access to the Customer Functions of a smart meter. The MDP will provide direct access to allow the CFSP to directly communicate with smart meters. Consistent with the SMI F.S. the smart meter installed by the MP will have full hardware and application (Function 23 & 24) interoperability in the smart metering infrastructure in order to work and allow for contestability in the service provision post mandate and minimise long term costs on consumers To ensure transition to contestability and competitive neutrality, two service providers will communicate with the smart meters (e.g. MDP and CFSP) and there will be protocols to regulate communications access to smart meters. The paper assumes that the CFSP is an accredited role by AEMO under the rules and operates outside of the Chapter 7 Responsible Person framework. The FRMP will have a contractual relationship with the LNSP, who will have rules obligations to ensure Service levels are met under monopoly arrangements during the mandate. CFSP contract/ rules obligations to the FRMP must include priority access conditions to meter control for the customer service functions. Emergency management protocols will need to be developed to cover access during emergency/network Security periods. (Definition for network security is required) 14

15 The CFSP will need to support the continuation of existing LNSP load management functions such as controlled hot water load/ ripple control. The introduction of new consumer centric load management functions (such as interruptible air conditioning) would be supported by the CFSP in accordance with load management protocols and guidelines which are yet to be developed. All connected communication networks are able to securely access the same system simultaneously or in parallel. Quoting from the interoperability paper15 produced by Martin Gill, states that: Contestability in the service provider role of meter data acquisition for types 1 to 4 meters already operate this way. For example most meter data providers use ITRON s MV-90 systems (or similar) to communicate with remotely read meters using a range of public telecommunications networks. The statements above suggest that multiple communication networks are currently being used to communicate with contestable type 4 meters. Definition of Function 24 ( i.e. interoperability of devices at device level) of the smart meter functional specification will further extend this ability of smart meters to talk to a variety of communication networks. Conflict of access can be managed easily by introducing priority of access depending upon what functionality is being accessed or requested. Consistent with the open access and contestability principles, this will allow for contestability of the provision of non-metrology (CFSP) services during mandate and enable full-contestability in the Metrology and Non-metrology services provision post mandate. Option #2, Post Mandate: Responsible Person (FRMP) appoints Metrology Service Providers (MP & MDP) & the Non Metrology Service Provider (CFSP) Direct access for provision of Metrology & Non Metrology Services Post Mandate: The FRMP is the RP for the Metrology Services and directly appoints the CFSP for the Non Metrology Services. Figure 4 Option 2 post-mandate In this scenario, there are a number of assumptions: 15 The FRMP is the Responsible Person for the provision of Metrology and continues to directly appoint the CFSP for Non- Metrology Services The MP is responsible for installation and maintenance of the smart meter. The MP is responsible for installation and maintenance of the smart meter (Meter Management) and smart meter communications network. The CFSP is responsible for the provision of the smart metering Non Metrology functions NSMP Interoperability Meter Protocols v0.1.doc 15

16 The MDP will be responsible for acquisition of metering data from the smart meter and for making it available to AEMO, the LNSP, and FRMP and any other party authorised by the Customer. The CFSP will provide access to the Customer Functions of a smart meter. The MDP will provide direct access to allow the CFSP to directly communicate with smart meters. (For example, the MDP uses MV 90 to communicate with a meter via the public telecommunications network while the CFSP installs their own application software to communicate with the smart meter) Consistent with the SMI F.S. the smart meter installed by the MP will have full hardware and application (Function 23 & 24) interoperability in the smart metering infrastructure in order to work. Two service providers will communicate with the smart meters (e.g. MDP and CFSP) and there will be protocols to regulate communications access to the smart meter.the paper assumes that the CFSP is an accredited role by AEMO under the rules and operates outside of the Chapter 7 Responsible Person framework. The FRMP will have a contractual relationship with the CFSP and the CFSP will have rules obligations to ensure network security. CFSP contract/ rules obligations to the FRMP must include priority access conditions to meter control for the customer service functions. Emergency management protocols will need to be developed to cover access during emergency/network Security periods. (Definition for network security is required) The CFSP will need to support the continuation of existing LNSP load management functions such as controlled hot water load/ ripple control. The introduction of new consumer centric load management functions (such as interruptible air conditioning) would be supported by the CFSP in accordance with load management protocols and guidelines which are yet to be developed. All connected communication networks are able to securely access the same system simultaneously or in parallel Option #3: The FRMP is responsible for metering but must use the LNSP during mandates for the MP and MDP roles Direct access for provision of Metrology & Non Metrology Services during Mandate: In this option, the FRMP directly appoints all service provider roles- the MP, MDP and CFSP. However during the mandate the MCE transitional rule will provision for the LNSP to appoint the MP and MDP for the purposes of a mass rollout of smart metering infrastructure. In this scenario, the Responsible Person role would be replaced by the FRMP responsible for the end to end of a connection point for both metrology and non metrology services by default. Figure 1 Option 3 during mandate via transitional rule 16

17 In this scenario, there are a number of assumptions: The LNSP is appoints the MP and MDP during the mandate period only and via a transitional rule to the default arrangements Default arrangements allow for the FRMP to directly appoint the MP, MDP and CFSP post mandate The CFSP is appointed directly by the FRMP during the mandate All roles appointed by the LNSP must be on a competitive neutrality basis with ring fencing arrangements The MP is responsible for installation and maintenance of the smart meter (Meter Management) and smart meter communications network. The CFSP is responsible for the provision of the smart metering non metrology functions The MDP will be responsible for acquisition of metering data from the smart meter and for making it available to AEMO, the LNSP, and FRMP and any other party authorised by the Customer. The CFSP will provide access to the customer service functions of a smart meter. The MDP will provide direct access to allow the CFSP to directly communicate with smart meters. (For example, the MDP uses MV 90 to communicate with a meter via the public telecommunications network while the CFSP installs their own application software to communicate with the smart meter) Consistent with the SMI F.S. the smart meter installed by the MP will have full hardware and application (Function 23 & 24) interoperability in the smart metering infrastructure in order to work and allow for contestability in the service provision post mandate and minimise long term costs on consumers To ensure transition to contestability and competitive neutrality, two service providers will communicate with the smart meters (e.g. MDP and CFSP) and there will be protocols to regulate communications access to smart meters. The paper assumes that the CFSP is an accredited role by AEMO under the rules and operates outside of the Chapter 7 Responsible Person framework. The FRMP will have a contractual relationship with the LNSP as the Responsible Person who will have rules obligations to ensure service levels are met under monopoly arrangements during the mandate. CFSP contract/ rules obligations to the Responsible Person must include priority access conditions to meter control for the customer service functions. Emergency management protocols will need to be developed to cover access during emergency/network Security periods. (Definition for network security is required) The CFSP will need to support the continuation of existing LNSP load management functions such as controlled hot water load/ ripple control. The introduction of new consumer centric load management functions (such as interruptible air conditioning) would be supported by the CFSP in accordance with load management protocols and guidelines which are yet to be developed. In the Phase 1 NERA report they state: Interoperability for meters / devices at application layer allows requests and messages to be sent to the smart metering system by parties other than the party primarily responsible through a standard interface (e.g. MV90- type solution). This is achieved through having a standardised application layer utilising known device driver protocols. A common application layer allows one network management system to communicate with multiple smart metering systems. This ensures that the smart meter system operator is not locked into a separate proprietary network management system for each smart meter system. This has the potential to facilitate competition between manufacturers of network management systems. Interoperability at the application layer may also allow parties other than the meter owner or smart meter operator to access data from the smart meter. This may result in improvements in the customer transfer process. Also, quoting from the interoperability paper 16 produced by Martin Gill which states that, It is acknowledged that there may be issues associated multiple parties attempting to control a meter. These issues relate to the control of functions and can be solved by 16 NSMP Interoperability Meter Protocols v0.1.doc 17

18 coordinating access, so that only one party can control functionality, or only supporting read access to the meter (such as to acquire the meter s energy data17.) The statements above advocate that multiple parties can control various functions of the smart meter via a coordinated open access available through function 23 (i.e. the application layer of the OSI model on which the SM infrastructure is based on) and therefore, the suggested arrangement is feasible. Consistent with the SMI F.S., open access will allow for contestability of the provision of nonmetrology (CFSP) services even during mandate and enable full-contestability in the Metrology and Non-metrology services provision post mandate. Option #3: The FRMP is responsible for metering but must use the LNSP during mandates Direct access for provision of Metrology & Non Metrology Services Post Mandate: In this option, the FRMP directly appoints all service provider roles- the MP, MDP and the CFSP. Figure 1 Option 3 post mandate In this scenario, there are a number of assumptions: The FRMP directly appoints the MP and MDP and CFSP The MP is responsible for installation and maintenance of the smart meter (Meter Management) and smart meter communications network. The CFSP is responsible for the provision of the smart metering Non Metrology functions The MDP will be responsible for acquisition of metering data from the smart meter and for making it available to AEMO, the LNSP, and FRMP and any other party authorised by the Customer. The CFSP will provide access to the customer service functions of a smart meter. The MDP will provide direct access to allow the CFSP to directly communicate with smart meters. (For example, the MDP uses MV 90 to communicate with a meter via the public telecommunications network while the CFSP installs their own application software to communicate with the smart meter) Consistent with the SMI F.S. the smart meter installed by the MP will have full hardware and application (Function 23 & 24) interoperability in the smart metering infrastructure in order to work and allow for contestability in the service provision post mandate and minimise long term costs on consumers Two service providers will communicate with the smart meters (e.g. MDP and CFSP) and there will be protocols to regulate communications access to smart meters. 17 Chapter 7 of the National Electricity Rules already provides that a FRMP and Distributor can both have read access to acquire data from a remotely read interval meter. 18

19 The paper assumes that the CFSP is an accredited role by AEMO under the rules and operates outside of the Chapter 7 Responsible Person framework. The FRMP will have a contractual relationship with the LNSP as the Responsible Person who will have rules obligations to ensure service levels are met under monopoly arrangements during the mandate. CFSP contract/ rules obligations to the FRMP must include priority access conditions to meter control for the customer service functions. Emergency management protocols will need to be developed to cover access during emergency/network Security periods. (Definition for network security is required) The CFSP will need to support the continuation of existing LNSP load management functions such as controlled hot water load/ ripple control. The introduction of new consumer centric load management functions (such as interruptible air conditioning) would be supported by the CFSP in accordance with load management protocols and guidelines which are yet to be developed. In the Phase 1 NERA report they state: Interoperability for meters / devices at application layer allows requests and messages to be sent to the smart metering system by parties other than the party primarily responsible through a standard interface (e.g. MV90- type solution). This is achieved through having a standardised application layer utilising known device driver protocols. A common application layer allows one network management system to communicate with multiple smart metering systems. This ensures that the smart meter system operator is not locked into a separate proprietary network management system for each smart meter system. This has the potential to facilitate competition between manufacturers of network management systems. Interoperability at the application layer may also allow parties other than the meter owner or smart meter operator to access data from the smart meter. This may result in improvements in the customer transfer process. Also, quoting from the interoperability paper18 produced by Martin Gill which states that, It is acknowledged that there may be issues associated multiple parties attempting to control a meter. These issues relate to the control of functions and can be solved by coordinating access, so that only one party can control functionality, or only supporting read access to the meter (such as to acquire the meter s energy data 19.) The statements above advocate that multiple parties can control various functions of the smart meter via a coordinated open access available through function 23 (i.e. the application layer of the OSI model on which the SM infrastructure is based on) and therefore, the suggested arrangement is feasible. Consistent with the SMI F.S., open access will allow for contestability of the provision of nonmetrology (CFSP) services even during mandate and enable full-contestability in the Metrology and Non-metrology services provision post mandate. 18 NSMP Interoperability Meter Protocols v0.1.doc 19 Chapter 7 of the National Electricity Rules already provides that a FRMP and Distributor can both have read access to acquire data from a remotely read interval meter. 19