NSMP Gap Review Analysis of Procedure Limitations

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1 GRAPL No: NSMP23 Status: Draft/Final Version: 0.7 Date: 05 Jul 2010 Short Title Function #7.23 Operating Conditions Deleted: 6 Deleted: 7 Jun NEM Procedures Impacted Metrology Procedure Metrology Procedure Part A Metrology Procedure Metrology Procedure Part B MSATS CATS Procedure MSATS MDM Procedure MSATS WIGS Procedure MSATS ROLR Process Part A B2B Procedure Customer Site Details Notification B2B Procedure Meter Data Process B2B Procedure Service Order Process B2B Procedure Technical Delivery Specification B2B Procedure Technical Guidelines B2B Procedure One Way Notification B2B Procedure ROLR Process Part B Other NEM Documents Meter Churn Guidelines Other NEM Documents Meter Churn Data Management Rules Other NEM Documents Meter Data File Format Specification Other NEM Documents Meter Data File Format Clarification Other NEM Documents MDA Nomination Rules Other NEM Documents Service provider Registration Procedure Other NEM Documents Service Provider Accreditation - Overview Other NEM Documents MDM file format & load process procedure Other NEM Documents Service Level Requirements MPD 5,6,7 Other NEM Documents Service Level Requirements MPC 5,6 Other NEM Documents Service Level Requirements MDA 1,2,3,4 Other NEM Documents Service Level Requirements MPA&B 1 to 6 Other NEM Documents Standing Data for MSATS Other NEM Documents Exemption Procedure Other NEM Documents Metering Data Delivery Dates (Calendar) Other NEM Documents NMI Procedure Other NEM Documents Service Provider Compliance Assessment Other NEM Documents Guide to the Role of the Responsible Person Page 1 of 5

2 Other NEM Documents Guideline for clarification of the NM Act Other NEM Documents Guidelines for Metering installation Security Other NEM Documents Metering Asset management Plan Other NEM Documents Allocation of Embedded Network Codes Other NEM Documents Distribution Loss Factor Codes in MSATS Other NEM Documents NEM Transmission Node Identifiers Other NEM Documents Retail Transfer Statistical Data Specification? Other NEM Documents BDPIP Process Flowchart New or altered procedure required. Background Information Limitations with existing NEM Procedures The setup and operating of Smart Metering Infrastructure may be limited if there are no changes made to the existing electricity market business process and procedures. The operating limitations with existing procedures to accommodate the smart metering infrastructure are detailed below. Grade A Amendments to NEM Procedures: NEM Metrology Procedure Part A Limitation #1: In clause 1.9.1, the diagram requires updating for exclusive role of DNSP during mandated rollout. Limitation #2: Provision for repairs in less than 10 business days in schedule 1 point 5.12 (2) would need to change to align with mandated service levels. SLR for MDA (metering installation types 1 to 4) Limitation #3: I am not sure whether checking for missing data can always occur before loading into the MDP metering database. Limitation #4: In clause 2.4.3, I am not sure whether checking for missing data can always occur before loading into the MDP metering database. Limitation #5: Clause 5.4.1(b): the requirement to aggregate import and export energy into a net datastream may need to be altered to accommodate PV generation when Smart Meters are in use. Grade B Additions to NEM Procedures: SLR for MPB (metering installation types 1 to 6) Limitation #6: In clause 4.12, the requirement for compulsory communication between the MP and the MDP does not permit the MP to utilise the benefits of the Smart Meter technology, especially tamper detection alarms. New or altered procedure required Limitation #7: Metrology Procedure Part A could be enhanced. The activities for 'Validate connection point data' should be included in a National Procedure to ensue Smart Meters are delivering reliable remotely read interval data before being registered in the market. Comment [T1]: Was comment 1. No issue with this clause. This clause only states that the MDP must have the capability to aggregate import and export energy, but it does not state when it must be done. contributors. the clause was not favourable to the retailer s interests. It was concluded that this Limitation should be retained. Explanation sent to BO 02/06/10 for consideration. Limitation #8: Two points (associated with procedure #24 (SLR for MDA): Page 2 of 5

3 Page 3 of 5 (a) (b) Clause 8.1.5(a): The first audit needs to be conducted earlier. It is just not 3 reads per premise in 6 months, it is 183 daily reads times 48 hh intervals. Since it is significant, any data which is incorrect or wrong will lead to disastrous recovery if not corrected in the first 15 days rather than 6 months. Clause 8.3.1: This is a generalised section. The clause should mention a reasonable period for reporting from MDP relating to data and timeliness of deliverables. Since the volume of data is very high, there will be no compliance to provide the data in a timely manner (which will defer the purpose of HH data delivered daily) unless NEMCO reporting and penalties for not delivering on time are enforced as a performance monitoring measure. Limitation #9: Two points (associated with procedure #24 (SLR for MDA): (a) (b) Clause 2.4 does not cover Event Log data relating to metrology. This point needs to be dealt with. Clause does not cover 4 quadrant metering data, which should be added, in addition to 'reactive energy'. Limitation #10: In clause 3.4 of Procedure#24 (SLR for MDA) the MDP should make sure the MDFF and the MDM are correctly populated with the latest information and the Register ID relates to the NMI suffix and all this information is mandatory rather than being optional. Grade C New Issue (with possible changes to IT or principles): NEM Metrology Procedure Part A Limitation #11: In clause 3.3, when a Smart Meter is installed, it must be able to be manually read as a type 6 meter first off, and after a transition period converted to a remotely read meter. This point may require a clarification of principles. NEM Metrology Procedure Part B Limitation #12: The current validation rules are too onerous for domestic customers with interval meters when power outage information indicates that there is no metering data for a period. Meter data validation is required to provide a level of assurance that the meter data represents the energy flow at the connection point. There are a number of different validation methodology, with some more suitable to a certain connection point. Meter data validation exceptions require manual analysis, which is time consuming and impacts on the cost of providing the service and the ability to deliver meter data in a timely manner. An analysis needs to be done to ensure that the validation methods are appropriate for the types of customers of smart metering (some classes of customers require different validation rules). B2B Procedure: Technical Delivery Specification Limitation #13: Currently, in accordance with clause 4.1, data is delivered through the B2B HUB. Is the capacity and timeliness still suitable in the SMI environment to support adequate levels of customer service? Clause 4.10 of the B2B Procedure Technical Service Delivery Specification contains service Comment [T2]: Was comment 2. This clause is from the SLR for Type 1-4, which includes NMIs with very high consumption and generators. If the current auditing cycle is acceptable for these types of NMIs, then it should be acceptable for NMIs with smart meters. To help alleviate the concern raised here, a suggestion is to have each participant demonstrate compliance with market rules/systems prior to accreditation which for the purpose of the NSMP is covered by the TFWG. contributors.... Comment [T3]: Was comment 3. This is already covered in clause 5.6 (Delivery performance of metering data). contributors. comments provided by AGL. A request for... Comment [T4]: Was comment 5. Please provide examples of when it is not correctly populated. this limitation, with subsequent change to the description of the limitation if possible (for example, is enforcement the issue).... Comment [T5]: Was comment 6. Latest information is already a requirement of the MDFF, see clause of the MDFF Spec. Latest information must be provided in the MDM, otherwise MSATS will reject the meter data. this limitation, with subsequent change to... Comment [T6]: Was comment 7. Register ID is currently mandatory for type 5 and not required for type 1-4. What is the impact if register id is not provided? contributor and better explain the impact to clarify if there is a limitation. comments provided by AGLEMO. A... Comment [T7]: Was comment 8. NMI Suffix is already mandatory. this limitation, with subsequent change to the description of the limitation if possible (for example, is enforcement the issue). comments provided by AGL. A request for...

4 levels for three different priority levels. These level may not support the retailer service requirements in a smart meter environment. Meter Data File Format Specification Limitation #14: In clause 4.3, if the Smart Meter is considered as a Type 4 file format: Record 200, The RegisterID is NotRequired for Types 1-4. It is desirable to have it "Mandatory" to align with the CATS standing data in the CATS_Register_Identifier table SUFFIX which should be Mandatory as well. May require a change to IT or clarification of principles. Limitation #15: In clause 4.5, if the Smart Meter is considered as a Type 4 file format: Record 400, changes are required to Appendix E, Section 10. the events list needs to be appended to include quality of supply, Customer Supply monitoring, Load Control, S/W upgrade and Plug and play device commissioning events. May require a change to IT or clarification of principles. Limitation #16: In clause 4.6, if the Smart Meter is considered as a Type 4 file format: Record 500, the Transcode in Appendix A, Sec 6, specifies the Service Order. In order to Align with smart meter, It would be desirable to add "Remote" as a field (with Reen, Deen, Meter Reconfig) if done remotely. May require a change to IT or clarification of principles. Limitation #17: In clause 5.2, if the Smart Meter is considered as a Type 4 file format: Record 100 Index read for type 4 meter will be required. May require a change to IT or clarification of principles. SLR for MDA (metering installation types 1 to 4) Limitation #18: Limitation #19: Limitation #20: Limitation #21: Limitation #22: Limitation #23: Rule (a) requires AEMO to be responsible for the remote acquisition of metering data. This point may require a clarification of principles. In clause 5.7.2, prudential requirements for data may be different for Type 4 - Smart Meter. This may require a clarification of principles. As per explanation provided in topic #16 (#2-SubData): In clause 1.7, specifically 1.7.2(c) and 1.7.3(a) & (b) & (h), the current rules for validation and substitution require a 'final substitute' be replaced by 'actual' metering data when a meter quality data flag occurs. The volume of these changes maybe a problem for Smart Meters. Should this substitution be allowed? (see further explanation in #2-SubData). May require a clarification of principles. In clause 3.4, a possible new file type may be required. In clause 3.5, the parties to whom the information is sent may need to be altered. In clause 5.6.5, the timing of data delivery may need to change. A new or revised NEM procedure may be required. Comment [T8]: Was comment 9. Given that RegisterID is Not required for type 1 4, what is the impact of this to the participants. That is why is it desirable for this field to be mandatory? contributor and better explain the impact to clarify if there is a limitation. comments provided by AEMO. A request for further detail and explanation sent to SB & PL on 03/06/10. Comment [T9]: Was comment 10. This is a solution not a requirement. There are other solution options that should also be considered to ensure the best outcome. >> WGL 03/05/10: It was agreed that the Limitation should be changed to there is no mechanism to allow the quality of supply, customer supply monitoring, load control, S/W upgrade, and plug & play device commissioning event information to be available to participants. PE to discuss this change with the contributor and then rework any changed text back to the source documents.... Comment [T10]: Was comment 11. Disagree. The 500 line, which is where the transcode field would be presented is only for manual reads. Therefore it does not apply to type 1-4 nor should it be for smart meters. See clause 4.6 of the MDFF Spec. >> WGL 03/05/10: It was agreed that the Limitation should be changed to there is no mechanism to allow the quality of supply, customer supply monitoring, load control, S/W upgrade, and plug & play device commissioning event information to be available to participants. PE to discuss... Comment [T11]: Was comment 12. Clause 5.2 refers to NEM13, which is only applicable to type 6 meters. would check the wording of the Limitation#17 with the contributor. comments provided by AEMO. A request for further detail and explanation sent to SB & PL on 03/06/10. Comment [T12]: Was comment 13. Disagree. Index reads are provided with interval meter data if they were manually read, ie type 5 meters. Therefore provision of index reads do not apply to type 1-4. See clause 4.6 of the MDFF Spec. would check the wording of the Limitation#17 with the contributor. It was agreed to transfer the Comment to the Role Requirements Paper to test the soundness of that analysis.... Page 4 of 5

5 May also require a change to IT or clarification of principles. Limitation #24: In clause 5.6.8, market participants get two different files (NEM12 and MDN). This is an issue for the MDP because of: (a) The timing between AEMO and the FRMP versions, and (b) The need to send the same information twice - is this really needed? A single file will reduce pipeline traffic, resulting in lower fees for the MDP and hence the market. Clause of procedure SLR for MDA contains a Summary Data Delivery Table. This table requires two different file types to be provided by the MDA and represents the source of the problem. Page 5 of 5

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