METERING COMPETITION EMBEDDED NETWORKS METER REPLACEMENT PROCESSES PROCEDURE CONSULTATION PARTICIPANT RESPONSE PACK

Transcription

1 METERING COMPETITION EMBEDDED NETWORKS METER REPLACEMENT PROCESSES PROCEDURE CONSULTATION PARTICIPANT RESPONSE PACK Participant: Ausgrid:- ENERGYAP (LNSP) TCAMP (MPB) TCAUSTM (MDP) Completion Date: 31/05/2016

2 Table of Contents 1. Glossary and Framework Meter Data File Format Metrology Procedure: Part A Metrology Procedure: Part B MSATS Procedures: CATS Procedure Principles and Obligations MSATS Procedures: MDM Procedures MSATS Procedures: Procedure for the Management of Wholesale, Interconnector, Generator and Sample (WIGS) NMIs NEM RoLR Process Part A and B MSATS Procedure: RoLR Procedures NMI Standing Data Schedule Service Level Procedures for MDP Service Level Procedures for MP Other Issues Related to Consultation Subject Matter...139

3 1. Glossary and Framework Clause Heading Participant Comments Metering Competition Embedded Networks Meter Replacement Processes Chapter 1 Introduction The clause numbering is inconsistent within the document and generally not consistent with the other procedures. For example, Clause has lettered clause numbers (a, b, c and d), whereas clause uses dotpoints. 1.1 Purpose and Scope 1.2 Definitions and Interpretation Ausgrid propose the use of RP should be removed from all procedures. Technical Guideline documentation can advise that the RP Tag in MSATS is used for the Metering Co-ordinator Role. Participants reading documents for the first time in 5 years will be confused with the interchange of terminology between RP, MC, etc as they will not have the benefit of knowing the history of the change. Procedure Consultation - Participant Response Pack Page 3 of 139

4 1.2.1 Glossary Interpretation 1.3 Related Documents Chapter 2 Framework 2.1 The Role of the Retail Market in the NEM 2.2 Retail Electricity Market Procedures Metrology Procedure B2B Procedures If the Retail Electricity Market Procedures specifically exclude B2B, then why is B2B listed in the document MSATS Procedures CATS Procedures WIGS Procedures MDM Procedures RoLR Procedures Metering Services Procedures Service Level Procedures Meter Churn Procedures Chapter 3 Glossary ADL: The net electricity delivered through a metering Procedure Consultation - Participant Response Pack Page 4 of 139

5 point averaged over an extended period. Current MP: Definition is missing. End User: A person who acquires or generates electricity.. Meter Serial ID: The faceplate serial number that uniquely identifies. Meter Status: Definition is missing. NEM Retail Operations Contacts List: Definition is missing. New Retailer: Same as New FRMP. NSRD: Table 4-M is not the correct cross reference. NSRD v Scheduled Reading Date: What is the difference? Parent Name: Definition is missing. Register Identifier: Definition is missing. Procedure Consultation - Participant Response Pack Page 5 of 139

6 Retail Electricity Market Procedure: Definition is missing. Scheduled Reading Date: Is this the NSRD? TI: Definition is missing. This is already defined in Chapter 10. Validated: Definition is missing. Procedure Consultation - Participant Response Pack Page 6 of 139

7 2. Meter Data File Format Clause Heading Participant Comments Metering Competition Embedded Networks Meter Replacement Processes 0 General The following comments relate to the general construct of the document:- The word that is overused in the document. 1 INTRODUCTION 1.1 Purpose and Scope 1.2 Definitions and Interpretation 1.3 Related Documents 2 GENERAL RULES AND INFORMATION Clause (c): Replace must ensure with must use reasonable endeavours. 3 TECHNICAL INFORMATION Test Files: The clause that specified test files are available from AEMO upon request has been removed. 3.1 Version details Procedure Consultation - Participant Response Pack Page 7 of 139

8 3.2 File delivery Clause (a) (iii):. of the intended MDP, ENM or Registered Participant. 3.3 File construction Clause (a):. (Refer sections 4 and 5). Clause (a):. In Section 4.3. Clause (b): Index Read must be provided for active energy Datastreams (Wh) when collected (New): The procedure needs to clearly state which Index Read must be provided where more than one has been collected on the Interval Date. Ausgrid recommends it should be the last (or latest) only on the IntervalDate (c): Add. tamper (reason code 61) : The clause that specified the hierarchy (albeit subjectively) where more than one reason code exists against actual data has been removed. A table should be Procedure Consultation - Participant Response Pack Page 8 of 139

9 included to specify the hierarchy. Ausgrid suggests: (1) Tamper, (2) Power Outage and (3) Time Reset. Clause 3.3.6: Should read. Sections 4 and INTERVAL METER READING FILE SPECIFICATION AND VALIDATION (NEM12) 4.1 Blocking cycle Clause 4.1: Refer to Appendix G. 4.2 Header record (100) 4.3 NMI data details record (200) 4.4 Interval data record (300) Clause 4.4: Refer to Section Interval event record (400) Clause 4.5: Add. tamper (reason code 61). 4.6 B2B details record (500) Clause 4.6: This record is mandatory for metering installation types 4A and 5. Manual meter readings can be collected for all interval metering types. Procedure Consultation - Participant Response Pack Page 9 of 139

10 Table: Refer to Section Table: Replace where collected with when collected. 4.7 End of data (900) 5 BASIC METER READING FILE SPECIFICATION AND VALIDATION (NEM13) Clause 5.1: Refer to Appendix G. 5.1 Blocking cycle 5.2 Header record (100) 5.3 Basic meter data record (250) 5.4 B2B details record (550) 5.5 End of data (900) APPENDIX A APPENDIX B TRANSACTION CODES FLAGS FORMAT & UNIT OF MEASURE FIELD DETAILS APPENDIX C QUALITY FLAGS Table: Column 2 has no values. APPENDIX D METHOD FLAGS Table: Delete Appendix D. This is duplicated in Metrology Procedure Part B. Procedure Consultation - Participant Response Pack Page 10 of 139

11 APPENDIX E REASON CODES Reason 0: For use in the cases where another reason code is not reasonably suitable. Reason 25: Unable to locate Meter Reason 51: Metering installation no longer exists Reason 87: Delete Network. It is irrelevant whose tariff exists in the meter. APPENDIX F APPENDIX G APPENDIX H OBSOLETE REASON CODES (ONLY TO BE USED WHEN PROVIDING HISTORICAL DATA) SUMMARY OF FILE FORMAT AND BLOCKING EXAMPLE INTERVAL DATA FILE (NEM12) H.1 Actual interval - Remote read meter Title: Actual Interval Metering Data Metering Installation Types 1,2,3 and 4. Note: The use of Actual is no longer consistent with the changes made in other Procedure Consultation - Participant Response Pack Page 11 of 139

12 documents. Ausgrid recommend the retention of the term Actual. H.2 Substituted interval - Remote read meter H.3 Interval data type 5 Estimate H.4 Multiple NMIs and data streams, remote read meter (all actual data) H.5 Remote interval data Multiple QualityMethod/ReasonCode combination Title: Substituted Interval Metering Data Metering Installation Types 1,2,3 and 4. Title: Interval Metering Data Metering Installation Types 4A and 5. Title: Multiple NMIs and datastreams, Metering Installation Types 1,2,3 and 4 (All Actual data). Note: The use of Actual is no longer consistent with the changes made in other documents. Ausgrid recommend the retention of the term Actual. Title: Metering Installation Types 1,2,3 and 4 Multiple Quality, Method and reason Codes. H.6 Metering data for meter Title: Metering data for Procedure Consultation - Participant Response Pack Page 12 of 139

13 change with configuration change type 5 H.7 Transfer occurs on the NSRD for type 5 meter H.8 Meter change: type 6 to type 5 APPENDIX I EXAMPLE CONSUMPTION DATA FILE (NEM13) meter change with configuration change Metering Installation Types 4A and 5. Example: The Meter Serial Number on the day of meter churn (10/08/2004) should be METSER456 (x3). Title: Transfer occurs on the NSRD for Metering Installation Types 4A and 5 Clause H.7: Replace Next scheduled Read Date with NSRD. Title: Meter change: Metering Installation Type 6 to Type 4A or Type 5 Example: The Meter Serial Number for the NEM12 files should be MET34567 (x2). I.1 Actual read values I.2 Normal meter read with Estimate I.3 Meter read and meter Procedure Consultation - Participant Response Pack Page 13 of 139

14 change I.4 Historical Data values I.5 Transfer read APPENDIX J EXAMPLE OF USE OF THE REGISTER READ FIELDS Procedure Consultation - Participant Response Pack Page 14 of 139

15 3. Metrology Procedure: Part A Clause Heading 1 INTRODUCTION The following comments relate to the general construct of the document:- 1.1 Purpose and Scope 1.2 Definitions and Interpretation Participant Comments Metering Competition Embedded Networks Meter Replacement Processes The word that is overused in the document. Not all terms in this procedure are defined in the glossary. For example:- Act Retailer Retail Licence 1.3 Related Documents 2 DISPUTE RESOLUTION 3 RESPONSIBILITY FOR METER PROVISION Title: METERING PROVISION 3.1 Overall requirements Paragraph 1: It is not correct to assume MPs will always be Procedure Consultation - Participant Response Pack Page 15 of 139

16 the provider of the metering equipment. Metering equipment maybe be leased and/or provided by the customer (eg instrument transformers). Paragraph 1: Delete routinely. Paragraph 1: Replace metrology procedure with this procedure. Paragraph 3: Delete properly. Paragraph 3: Replace initially tested with commissioned. Paragraph 3: Replace metrology procedure with this procedure. 4 METERING INSTALLATION COMPONENTS 4.1 Requirement under National Measurement Act and use of Standards Heading: Replace and use of standards with and applicable standards. Paragraph 2: Why has (including transitional arrangements) been deleted Procedure Consultation - Participant Response Pack Page 16 of 139

17 from CT and not VT requirements? Paragraph 5: cumulative total energy for each published Datastream. 4.2 Use of optical ports and pulse outputs 4.3 Password allocation 4.4 x values calculation and use 4.5 y values calculation and use 4.6 Grandfathering 4.7 Data storage requirements for meters Question: Does this mean an MRIM meter can be installed on a business customer in NSW consuming between 100 MWH and 160 MWH pa? Is this a jurisdictional issue? If so, who is resolving it? Question: Does this mean an MRIM meter can replace a Basic meter on a business customer in NSW consuming between 100 MWH and 160 MWH pa? Is this a jurisdictional issue? If so, who is resolving it? Question: If we are going to duplicate the requirements Procedure Consultation - Participant Response Pack Page 17 of 139

18 specified in Chapter 7, then why not for all meter types? Otherwise delete. 4.8 Meters and clocks Paragraph 1: +/- 300s exceeds the Australian Standard albeit this is the value in the current version of the Metrology Procedure. 4.9 Interval Meters 5 MINIMUM SERVICES SPECIFICATION Paragraph 2: Incorrect clause reference Should be 4.2. General: The industry would benefit significantly from the end-to-end process being specified by way of a service level. This should be specified in the B2B Procedures. Paragraph 1: Poorly structured sentence. The sentence needs to indicate how a small customer metering installation becomes a type 4 metering installation by installing a minimum services specification meter. 5.1 Minimum Service Levels Clause 5.1.1: Replace lack of Procedure Consultation - Participant Response Pack Page 18 of 139

19 supply with loss of supply. Clause 5.1.1: Include communications availability as a pre-requisite for delivering the minimum services. 5.2 Completion Rates Clause 5.2: Should be clause Technical Requirements Dot-point 1: All metering installations must be capable of measuring active power (Wh) and leading and lagging reactive power (varh) for both import and export energy flows. Dot-point 2: Where in the Rules does it state these Installation Inquiry services are limited to polyphase meters only? Should read the meter should be capable of measuring the average current or voltage per phase. Note: The SI units for reactive energy is var, not VAr. 6 SUMMATION METERING New Clause: Summation metering, if deployed, should require a minimum of using Procedure Consultation - Participant Response Pack Page 19 of 139

20 summation CT s and also have the obligation that the overall accuracy requirement as per the NER s can be maintained. 7 EMBEDDED NETWORKS Table 1: The cross referencing is not correct. 8 REVERSION OF METERING INSTALLATION TYPES 9 ROUTINE TESTING AND INSPECTION OF METERING INSTALLATIONS Comment: Are the reversion policies relevant given Type 5 and Type 6 meters can no longer be installed? Refer to comments on x and y values. Is this a jurisdictional issue? If so, who is resolving it? Table 1: The cross referencing is not correct. 10 INSTALLATION OF METER(S) Paragraph 2: Why is type 4 included, but types 1-3 not? If the requirement is relevant for type 4 metering installations, it is equally relevant for types 1-3. Paragraph 5: If the tariff for a connection point changes Procedure Consultation - Participant Response Pack Page 20 of 139

21 and the metering installation is no longer capable of supporting the new tariff, the MC must Installation by ASPs Clause 10.1: Delete. No longer relevant. Refer to comments on x and y values. Is this a jurisdictional issue? If so, who is resolving it? 11 METER CHURN General: The structure of the clause should be more in line with a procedure not in the form a questions and answers Who can Initiate a Meter Churn 11.2 Who can Perform the Meter Churn 11.3 How is a Meter Churn to be Performed Clause 11.1: The Current MC for a metering installation can initiate Meter Churn at any time. Clause 11.2: Only MPs with the appropriate accreditation and approval from the current MC can perform Meter Churn. General: Given only an MP can perform meter churn, can the details of this be included in the MP SLP instead of the Procedure Consultation - Participant Response Pack Page 21 of 139

22 Metrology Procedure? The obligation for the MC to provide the information to the MP can still exist in this document, but the details should be defined only in the MP SLP. Clause (a) (ii): the Site address; Clause (a) (new): details of any load control devices. Clause (a) (new): details of any network devices. Clause (a) (new): details of any instrument transformers. Clause (a) (new): network tariff code(s) to be supported by the metering installation. Clause (a) (new): details of any access or safety issues. Clause (a) (new): details of any life support. 12 DE-COMMISSIONING AND REMOVAL OF METERING EQUIPMENT AND NETWORK DEVICES General: Given only an MP can perform meter churn, can the details of this be included in the relevant SLP instead of Procedure Consultation - Participant Response Pack Page 22 of 139

23 the Metrology Procedure? The obligation on the MC can still exist in this document, but the details should be defined only in the MP SLP or the MDP SLP (where relevant). Otherwise:- (a) Before de-commissioning all or any part of an existing metering installation, the MP undertaking the work must ensure: i. For all metering, face reads of all registers are recorded and transferred to the relevant MDP within 2 business days; ii. For manually read interval metering, reasonable endeavours are made to minimise the loss of interval data by scheduling the meter churn as close to, but after, the NSRD as Procedure Consultation - Participant Response Pack Page 23 of 139

24 practicable; iii. For remotely read interval metering, reasonable endeavours are made to achieve a final interval read up to the time of meter removal. (b) The ownership of the existing meter is ascertained and arrangements made for the meter to be returned to its owner in an agreed condition within 10 business days unless otherwise agreed with the LNSP owner. Paragraph 2: Delete. Refer to re-wording above Network Devices Comment: Network Devices should be a clause of its own. Clause : For the purposes of clause of the NER, an existing metering installation that is to be replaced by an MC will be Procedure Consultation - Participant Response Pack Page 24 of 139

25 treated as a network device only if the metering installation is doing something other than supporting the application of a network tariff. Comment: Where a load control unit (LCU) is being used it is supporting the application of a network tariff by controlling the hours of operation of the load. Using this definition a LCU is not a network device! Clause (b) (i): Contradicts clause regarding the supporting the application of the tariff. Clause : Heading should be LNSP Obligations if Alterations to a Network Device is Metering Installations Required Is it an alteration or an isolation of the metering installation? I would have thought that only the current MP would be able to alter the Procedure Consultation - Participant Response Pack Page 25 of 139

26 metering installation. This whole clause needs to be reviewed to outline what the alteration/isolations issues are. Clause (a): Prior notification may be impractical where an LNSP is called out to a customer premise for no hot water. If it is a faulty LCU the unit is bridged out and scheduled for replacement. Clause (b): In many emergency situations the LNSP officer is not an authorised officer of the MP. Clause (c): There should be a reverse obligation for the MP/MC to notify the LNSP when they break seal on a Network Device. Clause : And the network device returned to the LNSP as per clause 12. Question: It is arguable that a network device does not always form part of the Procedure Consultation - Participant Response Pack Page 26 of 139

27 12.2 Request for testing type 1 6 metering installations 13 RESPONSIBILITY FOR METERING DATA SERVICES metering installation Refer Chapter 10. The definition of a network device suggests it may be located at or adjacent to a metering installation Is this correct? Comment: Clause does not exist Metering data services Paragraph 1: Delete or FRMP (where applicable). Only the MC can appoint an MDP Metering data collection Table 1: The table does not appear to support Metering Data Collection? Table 1: The cross referencing is not correct. Table 2: The table does not appear to support Metering Data Collection? Table 2: The cross referencing is not correct. Table 3: In what context is this table relevant? Table 3: The cross referencing Procedure Consultation - Participant Response Pack Page 27 of 139

28 is not correct. Table 7: The cross referencing is not correct. Paragraph 6: The cross referencing is not correct (x2). Paragraph 8: The MC must use reasonable endeavours to ensure energy data is collected from a type 4A, 5 or 6 metering installation no more than two business days prior to, or two business days subsequent to, the Scheduled Read Date for that metering installation Paragraph 10: Should this be LNSP or TNSP? What is the context? Clause numbering! Paragraph 10: Replace ensure with use reasonable endeavours. New Paragraph: The MC must use reasonable endeavours to ensure energy data collected from a type 4A, 5 or 6 metering installation is transferred to the relevant Procedure Consultation - Participant Response Pack Page 28 of 139

29 13.3 Metering data storage metering data services database within one business day of the energy data being collected from the metering installation Access to energy data and metering data 13.5 Verification of metering data for type 4A, 5, 6 and 7 metering installations 13.6 Metering installation type 7 sample testing 13.7 Request for test of calculated metering data 13.8 AEMO s Metering Data Obligations Table 1: The cross referencing is not correct. Paragraph 2: The MC must ensure doesn t make sense. Needs to be reworded. Paragraph 1: Replace determining with determined. Table 3.8: Why is this table the only one in the document with a distinct Table Number? Paragraph 2: with Section 11 Procedure Consultation - Participant Response Pack Page 29 of 139

30 14 EMERGENCY PRIORITY PROCEDURES 14.1 Criteria for determining Emergency Condition 14.2 Metering Installations Affected 14.3 Prioritisation of Services by Metering Coordinator in Emergency Condition Comment: The governance and detail regarding the EPPs is not clear and needs to be defined and published. Clause 14.2: Aren t the EPPs relevant to minimum specification meters only? 14.4 Other Laws Prevail Clause 14.4: The application of the EPPs may impact compliance with the NER such as the ability to acquire and provide metering data, etc. Procedure Consultation - Participant Response Pack Page 30 of 139

31 4. Metrology Procedure: Part B Clause Heading Participant Comments Metering Competition Embedded Networks Meter Replacement Processes 1 INTRODUCTION The following comments relate to the general construct of the document:- The word that is overused in the document. The removal and/or absence of clause numbering is not consistent with other procedures and in some instances has altered the intent of the procedure. The way metering installation types are described is not consistent. Ausgrid suggests. type x, y and z metering installations should be used consistently. Procedure Consultation - Participant Response Pack Page 31 of 139

32 1.1. Purpose and Scope 1.2. Definitions and Interpretation The glossary term Actual Meter Reading should be applied throughout the document instead of the long-winded Rules definition. In some instances, the use of the rules definition has changed the intent of the requirement. There are several clauses where the alphabetical clause numbering restarts within the clause. For example, clause 5.2 has 4 x (a) and 4 x (b) numbered clauses. If only for the purposes of cross referencing, the sub-clause numbering should not re-start within a clause Related Documents 2 PRINCIPLES FOR VALIDATION, SUBSTITUTION Procedure Consultation - Participant Response Pack Page 32 of 139

33 AND ESTIMATION 2.1. General Validation, Substitution and Estimation Requirements Paragraph 2: including any liaison with MDPs, MPs, ENMs and Register Participants. Paragraph 3: Delete, therefore,. Paragraph 4: New paragraph required from The MDP must apply Substitution requirement Paragraph 1: Delete that is. Clause (a): Where the system or equipment supporting the remote. Clause (e): Where metering data is found to be erroneous. Clause (f): Delete. This is covered in clause (g). Clause (h) (ii): NSRD. Clause (m): To support the requirements of the meter churn procedures Estimation requirement Paragraph 1: Delete that is. Clause (a): Delete that is. Clause (b): Section 13. Paragraph 2: Where the Procedure Consultation - Participant Response Pack Page 33 of 139

34 NSRD of a metering installation is changed due to a revised reading schedule, the MDP must ensure forward estimated metering data exists beyond the revised NSRD. There is no need to re-estimate if sufficient estimated data already exists. Table: Schedule 3.10 Table: Apply the correct title for the MDP SLP Metering data quality flags Table: Use the defined term Actual Meter Reading when describing A, S, E and F quality data. Paragraph2: Section 2.4(f). Paragraph 2: Sections 2.4(b) or 2.4(h). Clause (b): Use the defined term Actual Meter Reading (x2). Clause (g): Use the defined term Actual Meter Reading. Clause (h): Use the defined term Actual Meter Reading. This clause is in support of the Log A when replacing final Procedure Consultation - Participant Response Pack Page 34 of 139

35 2.5. Summary table of Substitution and Estimation Types 3 SUBSTITUTION FOR METERING INSTALLATION WITH REMOTE ACQUISITION OF METERING DATA substituted data. Clause (h): Delete by agreement with the FRMP, the LR and the LNSP. The page number for Type 20 is missing. Clause 3: SUBSTITUTION FOR TYPES 1,2,3 AND 4 METERING INSTALLATIONS. The change of title detracts from the meaning as type 5 and 6 meters can be read remotely Application of section 3 Paragraph 1: Delete for metering installations with remote acquisition of metering data Substitution Rules Paragraph 7: New paragraph required from MDPs may change the quality flag. Paragraph 8:. the LNSP, the LR and the FRMP. Paragraph 8: Use the defined term MDFF. Paragraph 9: Delete contents of parentheses. The new standard is to no longer Procedure Consultation - Participant Response Pack Page 35 of 139

36 duplicate Rules requirements in the SLPs. Paragraph 10: Use the defined term Actual Meter Reading Substitution Types Type 11 Paragraph 1: Italicise interval metering data. Type 13 (a): Amend to include the ability to use SCADA data from sources other than AEMO. Type 16: In the industry workshops it was generally agreed the Type 16 substitution method is not required. MDPs should be allowed to complete substitutions using one of the specified methods, regardless of the period, and then use a Type 18 in the event the market participants agree an alternative method should be employed. The Type 16 methodology will be made redundant by global agreements so as to avoid individual applications. So why have it? Type 17:. for periods up to Procedure Consultation - Participant Response Pack Page 36 of 139

37 4 SUBSTITUTION AND ESTIMATION FOR MANUALLY READ INTERVAL METERING INSTALLATIONS two hours.. Type 20: This doesn t work. This method is required because the MDP doesn t have access to any historical data. So any reference to use data from the corresponding day in the previous week, or an earlier day in the same week, simply doesn t work. The only days the table allow to work properly are Tuesdays and Wednesdays. The text needs to simply say. from the corresponding day the following week.. If alternatives are required for (say) public holidays, then a new table is required to where all the reference days are forward of the substitution day. Clause 4: SUBSTITUTION AND ESTIMATION FOR TYPES 4A AND 5 METERING INSTALLATIONS The change of title detracts from the meaning as type 1, 2, 3 and 4 meters can be read manually. Procedure Consultation - Participant Response Pack Page 37 of 139

38 4.1. Application of section 4 Paragraph 2: Delete 4.2. Substitution and Estimation Rules 4.3. Substitution and Estimation Types 5 SUBSTITUTION AND ESTIMATION FOR METERING INSTALLATIONS WITH ACCUMULATED METERING DATA Paragraph 1: Use the defined term Actual Meter Reading. Paragraph 6: the LNSP, the LR and the FRMP.. Paragraph 7: the LNSP, the LR and the FRMP.. Table 4 Paragraph 1:. four weeks, or part thereof Application of section Substitution and Estimation Rules 5.3. Substitution and Estimation Types Table 4 Paragraph 4: Type 52 Alternative.. Clause 5: SUBSTITUTION AND ESTIMATION FOR TYPE 6 METERING INSTALLATIONS The change of title serves no purpose and needs to change to be consistent with the changes required to clauses 3 and 4. Clause (a): Use the defined term Actual Meter Reading. Otherwise delete or interval metering data. New Method: A new substitution method is Procedure Consultation - Participant Response Pack Page 38 of 139

39 6 SUBSTITUTION AND ESTIMATION FOR CALCULATED METERING DATA required to allow the MDP to pro-rata an Actual meter reading where the reading overlaps a transfer read and is less than the transfer read. This method is required to support ROLR and will be further required if we allow transfers on estimated or customer readings Substitution Rules 6.2. Substitution and Estimation Types 7 GENERAL DATA VALIDATION REQUIREMENTS Restructure clause to incorporate 3 distinct requirements:- General Validation Requirements Validation of Interval Metering Data (from section 10) Validation of Interval Metering Data Alarms 7.1. Validation requirements for See comment above. Procedure Consultation - Participant Response Pack Page 39 of 139

40 all metering installations 7.2. Validation of interval metering data alarms 8 VALIDATION WITHIN THE METER READING PROCESS General: The service levels or validation parameters need to be specified. If MDPs can t be provided with what needs to be validated, then there s no value in having these rules. The meter alarms need to be segregated into configuration types:- All Meter Configurations Pulse Overflow (Y/N) CRC Error (Y/N) Time Tolerance (Part A) Three Phase Configurations VT or Phase Failure Performing phase or power failure validation on single phase installation is too onerous and does not apply to the millions of Type 6 meters currently installed. Paragraph 4: Delete Duplicate of paragraph 1. Procedure Consultation - Participant Response Pack Page 40 of 139

41 8.1. Validations to be performed during collection of metering data from manually read interval metering installations 8.2. Validations to be performed during collection of accumulated metering data 9 VALIDATION AS PART THE REGISTRATION PROCESS General: The clause needs to be restricted to contain 4 distinct sections:- General Requirements The MDP must establish processes and procedures in conjunction with the MP to ensure:- The NMI is registered in MSATS; The NMI is correct for the relevant NSP; The metering data pertains to the correct metering installation; All datastreams are captured; and All datastream assignments are correct. Procedure Consultation - Participant Response Pack Page 41 of 139

42 Remote Communications The MDP must establish processes and procedures in conjunction with the MP to ensure:- Details of the communications equipment are correctly recorded; and The communications equipment is functional. Whole Current Metering The MDP must establish processes and procedures in conjunction with the MP to ensure:- The meter and pulse multipliers for the new metering installation are correct. Instrument Tx Metering The MDP must establish processes and procedures in conjunction with the MP to ensure:- The metering data acquired from the metering installation is of Procedure Consultation - Participant Response Pack Page 42 of 139

43 9.1. Validation metering installations with remote acquisition of metering data 9.2. Validation for manually read interval metering installations 9.3. Validation for metering installations with accumulated metering data 9.4. Validation for metering installations with calculated metering data 10 VALIDATION OF METERING DATA a magnitude consistent with the measured load at the time of installation (ie complete a Load Check). Add Load Check to the Glossary. See comments above. See comments above. Clause (e): What does this mean? Clause 9.3: Delete. There should be no need for this process (ie Basic Meters) in the future. Unless reversion is allowed. VALIDATION OF INTERVAL METERING DATA These validation requirements apply to interval metering data only. Can this clause be moved to section clause 7? Procedure Consultation - Participant Response Pack Page 43 of 139

44 10.1. General Clause 10.1:. to perform Validations in addition to those specified in Section 10 to ensure Validations to be performed for all metering installations Validations to be performed for metering installations with check metering or partial check metering Validations to be performed for manually read interval metering installations with CTs Validations to be performed for whole current manually read interval metering installations Clause (a): Delete. Adequately covered in (b). Clause (a): Delete. Duplicate of 10.2 (b). Clause (b): Delete. Duplicate of 10.2 (d). Clause (c): Delete. Duplicate of 10.2 (e). Clause (d): Move to 10.2 and delete all of clause Clause (e): Move to 10.2 and delete all of clause Clause (a): Delete. Duplicate of 10.2 (b). Clause (b): Delete. Duplicate of 10.2 (c). Clause (c): Delete. Duplicate of 10.2 (d). Clause (d): Delete. Duplicate Procedure Consultation - Participant Response Pack Page 44 of 139

45 10.6. Validations to be performed for metering installations with accumulated metering data Validations to be performed for metering installations with calculated metering data 11 LOAD PROFILING CONVERSION OF ACCUMULATED METERING DATA Requirements for load profiling Profile Preparation Service - Controlled Load Profile Basic Meter Profiler Controlled Load Profile Preparation Service - Net System Load Profile Basic Meter Profiler - Net System Load Profile of 10.2 (e). Clause (e): Move to 10.2 and delete all of clause Clause (f): Move to 10.2 and delete all of clause Procedure Consultation - Participant Response Pack Page 45 of 139

46 11.6. Start Dates and End Dates 12 UNMETERED LOADS DETERMINATION OF METERING DATA Requirement to produce calculated metering data Controlled Unmetered Loads Other unmetered loads ON delay and OFF delay Traffic signal dimming 13 SUBSTITUTION FOR TRANSFER General: The clause needs to be revisited in light of transfers on estimated readings. Reason Code 27 won t be appropriate in all instances Application Clause 13.1: Sections 13.2 and Manually read interval metering installations Clause (a): No need for free text with Reason Code. Clause (b): Delete. This is irrelevant. Paragraph 6:. all substituted and estimated metering data is replaced Manually read accumulation Clause (a): No need for free Procedure Consultation - Participant Response Pack Page 46 of 139

47 metering installations text with Reason Code. Clause (b) The 1 st one: Delete. This is irrelevant. Note: A new substitution prorata method is required to support the re-substitution in the event the next Actual is less than the final substitution. Refer to Section 5 comments. Procedure Consultation - Participant Response Pack Page 47 of 139

48 5. MSATS Procedures: CATS Procedure Principles and Obligations Clause Heading Metering Competition 0 General There are many obligations within the procedures where it specifically states (for example) the MC must. If it is proposed such obligations might be delivered by other parties, then the wording within the procedures should be changed to the MC must ensure to allow sufficient flexibility in other procedures to allow the obligation to be delivered by another party (albeit leaving the fulfilment of the obligation with the MC). QUICK REFERENCE GUIDE HOW TO USE THIS DOCUMENT 1 INTRODUCTION 1.1 PURPOSE AND SCOPE 1.2 DEFINITIONS AND INTERPRETATION Picture needs to be updated to Section instead of Chapter to be consistent with all other changes. Chapter still exists in various parts of the document and needs to be updated to Section. Participant Comments Embedded Networks Meter Replacement Processes Procedure Consultation - Participant Response Pack Page 48 of 139

49 1.3 COMMENCEMENT OF CHANGES 1.4 RELATED DOCUMENTS 2 OBLIGATIONS BY ROLE 2.1 GENERAL OBLIGATIONS Clause: (e): Delete the example. This is not consistent with the remainder of the document. 2.2 FINANCIALLY RESPONSIBLE MARKET PARTICIPANT Clause (i): reasonable time is not a defined period and should not occur in the procedures. Ausgrid believe that clause (s) should be removed from the document. The MC should be solely responsible for advising the LNSP and the FRMP upon completion of a remote disconnect or reconnect. Two parties must not have the same obligation. The MC has this obligation in 2.7(.c) Ausgrid request that a new clause is added against the New FRMP. (..new) Inform the LNSP when a connection point is to be remotely disconnected or remotely reconnected prior to the work being performed. Further to this point the remote disconnection and reconnection needs to be identifiable at a meter level, not the connection point. The above clause is required to ensure Procedure Consultation - Participant Response Pack Page 49 of 139

50 2.3 LOCAL NETWORK SERVICE PROVIDER Ausgrid does not reconnect a site that has been remotely disconnected when Ausgrid is contacted directly by the customer. General Comment: Ausgrid LNSP has concerns with the processes linked to new minimum services functionality, particularly how they will be automated and standardised to facilitate the update of MSATS with standing data. It is unacceptable to Ausgrid to be forced into delivering functionality to facilitate a process where Ausgrid is not directly involved. It is currently unclear how any processes will work to support minimum services functionality updates of MSATS. Reviewing the CATS documentation in isolation to industry procedures (B2B) will lead to inefficient outcomes for the market. Ausgrid ask that clause (e) be reworded as the timing of the ADL delivery has been removed. Provide the average daily load to the Current MDP or the new MDP upon request. The clause previously stated at the time of NMI creation. For example, Ausgrid does not accept that a current MDP could request the ADL for all sites after 5 years of the MDP managing a group of NMI s. (K) Ausgrid has reviewed the impacts to systems to include a new NMI Status of R. Procedure Consultation - Participant Response Pack Page 50 of 139

51 The NMI Status is a key component of system functionality, we estimate that the addition of the NMI Status code of R will at least cost $500,000 with no benefit to the LNSP as it impacts:- Meter Data Delivery Substitution and Estimation Datastream Processes Standing Data updates Service Order Functionality Customer Threshold update (g) System Reporting Other internal processes Ausgrid notes that the disconnection method (Remote in this instance) is not represented in MSATS for any other disconnection types (Pole Top / Main Switch / Fuse etc). Ausgrid believe alternate update methods to reflect the remote disconnection are available and should be considered against a cost benefit analysis. Alternate update methods directly reflect the action taken by participants involved in the minimum services transaction. Alternate Solution: Under the new procedures Market Procedure Consultation - Participant Response Pack Page 51 of 139

52 Participants must use Standing Data stored at the Meter Level to determine if a meter is capable of minimum services functionality e.g. Meter Installation Type of COMMS4D. Ausgrid therefore propose that a remote disconnection could be represented in MSATS at the Meter Level using a new Meter Status of D Disconnected Remotely. Benefits of the alternate solution include:- All Market Participants are advised of the remote transaction via existing Change Requests (CR30xx) Market Participants can choose if they update backend systems with functionality to show remote disconnections / reconnections. MSATS updates are reflective of participants that are part of the minimum services transaction e.g. MPB or MC would need to update the Meter record in MSATS, LNSP is not involved. Costs to Market Participants not involved in the minimum services transaction are minimal (MDP, LNSP). The alternate solution gives the ability to show instances where only a single meter is remotely disconnected. Procedure Consultation - Participant Response Pack Page 52 of 139

53 2.4 LOCAL RETAILER Ausgrid estimate the cost to implement the alternate solution to be $30,000 a saving of at least $400, METERING DATA PROVIDER Clause (h): Use the defined term, not estimate. 2.6 METERING PROVIDER CATEGORY B Clause (k): Add 4A. Clause (q): Add 4A. Clause (a): Add 4A. Clause (f): Delete Status Code. 2.7 METERING COORDINATOR Ausgrid propose an update to the existing clause 2.8 RETAILER OF LAST RESORT 2.9 SECOND NETWORK SERVICE PROVIDER (c) Inform the LNSP and FRMP when a meter(s) is disconnected or reconnected remotely within 1 business day AEMO Ausgrid requests that AEMO use logic within the NMI ranges / sets provided in (h). For example, embedded networks in the Ausgrid area currently have a NMI of 4104xxxxxx. The first four characters of the NMI should be reflective of the Jurisdiction and Network to which the parent is connected. Procedure Consultation - Participant Response Pack Page 53 of 139

54 2.11 EMBEDDED NETWORK MANAGER 3 CATS FUNCTIONALITY 3.1 OVERVIEW 3.2 PRINCIPLES 3.3 TRANSACTION TYPES General: The entire clause is poorly constructed. Clause (e) The 2 nd one: Duplicate of clause (a) The 4 th one. 3.4 CHANGE REQUESTS Table 3B: Delete CR Codes as per later comments. 3.5 CHANGE REQUEST STATUS LIFE CYCLE 3.6 TRANSACTION VALIDATION 3.7 VALID PROPOSED CHANGE DATE FOR PROSPECTIVE AND RETROSPECTIVE CHANGE REQUESTS 4 CATS CODES AND RULES FOR A CHANGE REQUEST Table 3C: Delete CR Codes as per later comments. Table 3D: Delete CR Codes as per later comments. 4.1 INTRODUCTION 4.2 CHANGE REASON CODE Table 4A: Delete CR Codes as per later comments. 4.3 ROLE CODES 4.4 CHANGE REQUEST Procedure Consultation - Participant Response Pack Page 54 of 139

55 INITIATION RULES 4.5 JURISDICTION CODES 4.6 TIMEFRAME RULES 4.7 OBJECTION CODES Ausgrid does not support the removal of the BADMETER Objection Code. Ausgrid use the Objection Code of BADMETER in the scenario below: CR1000 or CR1080 Read Type Code is NS, RR, SP, PR, ER Our Systems are the MDP COMMS Meters exist Our systems have over 250 objections using this code since the start of the year. We expect this number to grow as the number of interval meters increase. The MDP is entitled to object using BADMETER in this instance. If the Objection Code is removed we will be forced to use DECLINED. If the resultant outcome is still an objection isn t it better to use BADMETER to more correctly define the objection? BADMETER is also relevant in the future where CR1000 is raised with a NEW MDP and Read Type Code of NI. A FRMP cannot initiate meter churn, this is not compliant with the Meter Churn rules. Procedure Consultation - Participant Response Pack Page 55 of 139

56 4.8 OBJECTION RULES 4.9 NMI CLASSIFICATION CODES BADMETER is also relevant in the future where MRAM metering exists and a participant uses a Read Type Code of EI. The removal of this code is to the detriment of the industry END USER CLASSIFICATION Table 4-G: There is no MEDIUM customer threshold code in NSW. Furthermore, the table should list the available values per jurisdiction similar to Table 4-E STATUS CODES (NMI AND DATASTREAM) See 2.3 above for Ausgrid s proposal for NMI Status Code of R As a prospective ENM Ausgrid questions the relevance of the N NMI Status. MSATS has the ability to identify an Off Market Child by comparing the FRMP of the Parent and Child NMI for settlements. Ausgrid does not agree with the requirement to update NMI Status when the FRMP changes on a Child NMI or Parent NMI. Ausgrid feels this change has been implemented to simplify settlements, not for the betterment of the market. Alternatively, this could be updated automatically by MSATS? Clause (c): Add MRAM and VICAMI. Procedure Consultation - Participant Response Pack Page 56 of 139

57 4.12 METERING INSTALLATION TYPE CODES Table 4L COMMS4. Note should simply read Meter is not capable of minimum services functionality. The date of installation is irrelevant as many metering companies will have minimum services metering in the field prior to December (.c) Please clarify the intent of the Manually Read Flag for Interval Meters? What does the Manually Read Flag mean for Non-Interval meters? An additional MSATS field to show if Minimum Service Functionality exists would remove the need for any new Metering Installation Type Codes. Will AEMO provide a cost benefit analysis on the different ways that this change could be implemented? Ausgrid suggest the following mandatory fields to be recorded at the Meter Level:- Transformer: Yes / No Minimum Services: Yes / No Remote COMMS: Yes / No Alternatively if AEMO insist on identifying the differences in Metering Installation characteristics using the Meter Installation Code then the MRAM code must have an MRAMC and MRAMD to be consistent with Procedure Consultation - Participant Response Pack Page 57 of 139

58 COMMS4C and COMMS4D READ TYPE CODE Table 4M needs to be updated for Read Type Codes NS, RR, SP, ER, CR and PR. Applies to types 4A, 5 and type 6 metering installations. NI must be removed from the table, it will not be allowed under the Meter Churn Rules. The FRMP must transfer with the existing metering FIELD VALIDATION RULES 4.15 CHANGE REQUEST STATUS NOTIFICATION RULES 4.16 MAINTENANCE OF CODES AND RULES Add: Network Tariff Code to the table. This is existing functionality 4.17 DATASTREAM STATUS CODE Clause (d): Should read. metering data is expected EMBEDDED NETWORK CODES AND RULES 4.19 OBTAINING ELECTRONIC DOWNLOADS OF CONFIGURATION RULES 5 CODES AND RULES FOR OTHER TRANSACTION TYPES Clause (c): The obligation should be on the ENM not the LNSP. The ENM must be the NSP2 on the parent NMI. 5.1 SEND CHANGE REQUEST Procedure Consultation - Participant Response Pack Page 58 of 139

59 STATUS NOTIFICATION 5.2 REQUEST PARTICIPANT DATA 5.3 RAISE OBJECTIONS 5.4 WITHDRAW A CHANGE REQUEST 5.5 WITHDRAW AN OBJECTION 5.6 REQUEST A NMI DISCOVERY SEARCH 5.7 PROVIDE A NMI DISCOVERY SEARCH RESPONSE 5.8 PROVIDE A CHANGE REQUEST RESPONSE 5.9 PROVIDE AN OBJECTION RESPONSE 5.10 PROVIDE AN ACKNOWLEDGMENT OF A TRANSACTION 5.11 ADVISE OF AN UPDATE TO A CODE OR RULE 5.12 REQUEST A REPORT The following information needs to be added to the C7 Report:- Network Tariff Code Meter Manufacturer Meter Model 5.13 GUIDELINES FOR MANAGING Procedure Consultation - Participant Response Pack Page 59 of 139

60 CONCURRENT RETAIL TRANSFERS 5.14 AEMO BULK CHANGE TOOL 6 CHANGE RETAILER SMALL OR LARGE NMI The procedures need to be structured differently, or new change request functionality provided, to deliver the new Meter Replacement / Meter Churn rules. The existing structure of the document is confusing and will end in ambiguous outcomes across the industry. For Example:- The CR1000 is a prospective transaction, therefore a FRMP is not entitled to nominate Service Provider Roles that are changing (if Service Provider Roles are not changing then there is no need to nominate them). Only the MC is allowed to change the MDP, the MPB and the MPC Roles. Nominating the MDP, the MPB and the MPC Roles in the CR1000 is changing them, because they will update contracts in MSATS when the MDP supplies the CR1500. The new MDP cannot supply the CR1500 until the meters have changed, otherwise they take ownership of data they cannot obtain or provide (BASIC to COMMS). The meters cannot change until the FRMP is in contract. Therefore the FRMP and MDP cannot change in a single prospective transaction under the current Procedure Consultation - Participant Response Pack Page 60 of 139

61 6.1 APPLICATION [ ] procedures. AEMO MUST submit a diagram that includes specific timing as to how they believe the new transfer processes will work and be compliant to the Meter Replacement Rules. 6.1 (a). Ausgrid would like to remove this clause, it has no relevance to this section. General: Ausgrid suggests a new prospective FRMP only Change Request is created to be used for existing Commas metering installations where the transfer will complete automatically on the Proposed Transfer Date unless a party objects (ie removing the need for the CR1500). The CR would require a read type code of EI. 6.2 INITIATION RULES 6.2.(i) The FRMP is not entitled to nominate the MDP in the CR1000 transaction. The MDP (MPB, MPC etc) must be nominated by the MC under the new rules. Ausgrid request AEMO to remove the creation of the Service Provider roles from the CR10xx transactions. Participants who add the MPB, the MDP and/or the MPC in a CR10xx should have their transaction Procedure Consultation - Participant Response Pack Page 61 of 139

62 Objected. AEMO must supply new Objection Codes for the new and current MDP / MPB if Service Provider Roles are not restricted. 6.3 OTHER OBLIGATIONS Clause (b): Delete paragraph 2. Clause (g) (3): If transfers on estimated/substituted readings are allowed to proceed, we need a new substitution method to pro-rata Basic meter readings in the event the next Actual is lower than the Final created for the transfer. Same problem with ROLR. ER is only acceptable for manually read meters (type 4a, 5 and 6). Clause (g) (4): What is the process by which the new FRMP advises the MDP? The obligation should be on the FRMP to provide the reading to the MDP, not the MDP to obtain it. There should be no obligation on the MDP to use the customer read in the event it fails validation. CR is only acceptable for type 6 metering? Clause 6.3.3: The obligation on the MC does not belong under the 10xx section. The MC obligation should be shown under the relevant Change Requests 6xxx. The procedure is stating how the change requests are structured by using, 6300 and 6700 (should be a CR6800). The nomination of the MDP is also required. The statement (c) Ensure that the name of the New MDP is recorded in MSATS using Change Reason Code 6200 prior to the Actual Change Date. is misleading. If an MC puts in a Prospective 6200 the MDP would always object, because the MDP party cannot ensure a prospective date is the day that a meter exchange occurs. CR6200 is rarely used today, clauses need to updated to support the new Meter Replacement rules to ensure MDP and MPB can only be updated on the meter exchange date. Procedure Consultation - Participant Response Pack Page 62 of 139

63 The MDP should be given the ability to raise a Change Request to confirm the Actual Change Date for the CR This would be in line with CR6800 functionality. The two Change Requests perform the same task from an MDP perspective. AEMO to consider the removal of CR62xx, 63xx, 67xx Change Requests and only use the CR6800 with special conditions dependent on the roles updated. 6.4 OPTIONAL REQUIREMENTS The NEW FRMP is not entitled to nominate the MPB or MPC in the CR1000 transaction. The MPB, MPC must be nominated by the MC under the new rules. Ausgrid request AEMO to remove the creation of the Service Provider roles from the CR10xx transactions. Participants who add the MPB, the MDP and/or the MPC in a CR10xx should have their transaction Rejected. 6.5 TIMEFRAME RULES 6.6 OBJECTION RULES 6.7 CHANGE REQUEST STATUS NOTIFICATION RULES 7 CHANGE RETAILER - ERROR CORRECTIONS Procedure Consultation - Participant Response Pack Page 63 of 139