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: AusNet Services (AST) 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...197

3 1. Glossary and Framework Clause Heading Participant Comments Metering Competition Chapter 1 Introduction 1.1 Purpose and Scope 1.2 Definitions and Interpretation Procedure Consultation - Participant Response Pack Page 3 of 197

4 1.2.1 Glossary Capitalised words, phrases and abbreviations set out in Chapter 3 have the meanings set out opposite them when used in this document and the Retail Electricity Market Procedures (except B2B Procedures). Italicised terms used in the Retail Electricity Market Procedures (except B2B Procedures) have the same meanings given to those terms in the NER unless otherwise specified. The first paragraph is difficult to read and understand. Suggest redraft more like second paragraph: Capitalised words, phrases and abbreviations used in the Retail Electricity Market Procedures (except B2B Procedures) have the meanings given to those terms in Chapter 3 of this document. have the meanings set out opposite them when used in this document and the Retail Electricity Market Procedures (except B2B Procedures) Interpretation 1.3 Related Documents Chapter 2 Framework Procedure Consultation - Participant Response Pack Page 4 of 197

5 2.1 The Role of the Retail Market in the NEM The physical production of electricity is carried out using various technologies and transported through high voltage transmission lines to distribution networks that operate at low voltage and deliver electricity to End Users at the required voltage. In financial terms, Generators who produce electricity in the NEM are required to sell their output through the spot market operated by AEMO (the NEM is a wholesale market). Retailers, referred to as Market Customers in the spot market, purchase this electricity from the spot market and then sell it to End Userss. FRC prevails throughout the NEM, which means that any End User can purchase electricity from a retailer of their choice. For this to work, however, it is necessary to have processes and systems that facilitate an orderly transfer of End Users from one retailer to another, and to ensure that payment streams are not disrupted. This is the function of the retail market. This is a somewhat restricted and settlement focussed view of the market framework as the impetus for the Retail Market Procedures. To provide a more complete description of the requirement for the Procedures, this Framework description should be expanded to include distributor billing and network analysis. Similarly the diagram should include the provision of metering data to the distributor data system and its support for network billing and network analysis. Further the diagram shows retailer billing being driven from MSATS data whereas the Metering Data is the key input into the End Use Bills 2.2 Retail Electricity Market Procedures Procedure Consultation - Participant Response Pack Page 5 of 197

6 The descriptions of the Metrology Procedure and the SLPs should more clearly provide the key ranges of coverage of the NER Chapter 7, Metrology Procedure and the SLPs. It would aid market understanding and ensure clarity of document purpose if the relative content of each of these three levels of the metrology documentation was clearly specified Metrology Procedure Maybe a good approach to achieving this would be to include some description of the relative roles and relationship of the MC and the MDP/MP B2B Procedures The MSATS Procedures are made under clause of the NER and are divided into a number of procedures, known as CATS, WIGS and MDM Procedures: MSATS Procedures This listing should be expanded to include the other MSATS documents: NMI Standing Data, NMI Procedures etc CATS Procedures WIGS Procedures MDM Procedures RoLR Procedures Metering Services Procedures Service Level Procedures Procedure Consultation - Participant Response Pack Page 6 of 197

7 Meter Churn Procedures Chapter 3 Glossary AEMO System Administrator BMP Business Group CATS Standing Data Access Child Name Current RP The AEMO person who creates the initial PA IDs for each Participant, with the PA Right assigned to each. PA ID and PA Right are not defined in this Glossary Basic Meter Profiler: The party that applies a profile, including NSLP or CLP, to determine trading interval data from accumulated metering data. trading interval is a NER defined term and hence should be in italics A group of Participant companies each with single Participant IDs that are part of a single entity. The term single entity is far from clear. This should be expanded to more clearly describe the relationship and the differences between the companies [presumably with different ABNs??] in the group. Rules See Tables 44-D, 44-E, 44-F, 44-G & 44-H in the CATS Procedures Table references are incorrect as per drafted CATS procedures The name given to a child connection point in MSATS Needs to be clarified by stating it needs to be the same as Parent Name The Metering Coordinator identified as the Current RP such on the NMI Master Record. Is the term Current RP still utilised in the Procedures? The definition is somewhat unclear. Should this rather read: The term used on the NMI Master Record to identify the Current Metering Coordinator. Final Reading Inventory Table This needs a Glossary entry. Eg Metrology Procedure A Section 12. A table of devices for unmetered loads associated with each NMI as described in sections and of Metrology Procedure: Part B. Table references are incorrect as per drafted Met B procedures Procedure Consultation - Participant Response Pack Page 7 of 197

8 Metering Alarm Metering Installation Meter Status Metering Data Verification Process Minimum Service Levels Any alarm situated within a metering installation designed to detect any unexpected occurrence, such as a loss of supply, VT or phase failure, tamper detection, reverse energy flow, pulse overflow, cycle redundancy check error and temperature or time tolerance. Think the description needs to state relevant alarms. The NER defines metering installation as: The assembly of components including the instrument transformer, if any, measurement element(s) and processes, if any, recording and display equipment, communications interface, if any, that are controlled for the purpose of metrology and which lie between the metering point(s) and the point at or near the metering point(s) where the energy data is made available for collection. It would appear that this definition is NOT satisfactory to define a metering installation which is providing smart meter services. The outcomes are no longer just for the purpose of metrology but for the broader outcomes of smart meter services and the communications interface is no longer where just energy data is available for collection but in fact where the broader range of smart meter services are available for collection. AusNet Services suggest that the Glossary should include a modification of the NER definition which encompasses these broader services. No description Suggest the status of the meter in MSATS. Eg current (C) or removed (R) The process by which a Participant queries the metering data received from an MDP and provide alternative metering data to the MDP for the purpose of Substitution. Do not believe the last part of this statement is correct, don t really understand what it is trying to achieve. The VMD process does not provide alternative metering data to an MDP for the purpose of substituting. This needs a Glossary entry. Eg Metrology Procedure A Section 5.1. Procedure Consultation - Participant Response Pack Page 8 of 197

9 MT PASA NEM Retail Operations Contact List Next Scheduled Read Date New MC medium term PASA Whilst medium term PASA is defined in the NER the acronym PASA is not defined?! This does not appear in any of the documents out for consultation. Which document does it appear in for Retail markets? If it doesn t appear in any of the documents remove it from the glossary. No description Contact list of relevant people in market participant businesses See Table 4M of CATS procedures Don t think the description in the CATS procedures adequately describes the NSRD. This needs a Glossary entry The process of finding a NMI and the NMI Checksum by searching MSATS using the Site, the DPID or a meter s serial number. See also the NMI Search Rules in section 44.3 of the CATS Procedures NMI Discovery Search 1 NMI Discovery Search 2 NMI Search Rules Parent Name Read Type Code Table references are incorrect as per drafted CATS procedures The process of finding a NMI and the NMI Checksum by searching MSATS using the Site, the DPID or a meter s serial number. See also the NMI Search Rules in section 44.4 of the CATS Procedures Table references are incorrect as per drafted CATS procedures See Table 44-B in the CATS Procedures. The search that is available in MSATS to enable a Participant identify a NMI when the only information available is the DPID, the meter serial number or the Site address. Table references are incorrect as per drafted CATS procedures Although a Glossary entry, no definition is provided. Types of meter readings detailed in Table 4-L of the CATS Procedures Table references are incorrect as per drafted CATS procedures Procedure Consultation - Participant Response Pack Page 9 of 197

10 Registration Retrospective Change Routine Testing Service Provider The status granted by AEMO to an MP or MDP at the completion of the accreditation process Do the Retailers need to be included here as well as they register with AEMO as well. A change to a NMI that is to be effective on or before the date the Change Request is submitted. Retrospective is today or before. For the purposes of the Metrology Procedure, includes the ongoing and regular maintenance testing, compliance testing and in-service testing of a metering installation initiated by the RP or MP to fulfil their obligations under clause S7.3 of the NER. Should say MC not RP An MDP, MP or LNSP. AusNet Services are unsure where the term Service provider is used, however in our view it is most often used in market documentation and communications as the group name for the MPs and MDPs. Eg the Service Providers appointed by the MC. Although the term Network Service Provider or LNSP is applied to Distributors, they are not generally grouped under the term Service Provider with the MDP and the MP. Although not recommended, if used in the broader sense, then presumably ENMs would also be grouped under the term. Procedure Consultation - Participant Response Pack Page 10 of 197

11 Site The physical location of an End User s premises. The move to change from premises to site has changed the meaning in at least one instance: Section 10 (c) available to the End User or any person whose obligation it is to test, adjust, maintain, repair, or replace the metering installation, or to collect metering data from the metering installation via safe, convenient and unhindered access when it is not located at the Site. However the use of the defined term "Site" rather the premises has taken away the intent of the clause as it was previously drafted. It was meant to ensure that where the MI was installed not within the area of a site (parcel of land) which was generally accessible by the End User ie not located at their premises, but located at the Site (ie at the address of the land on which their premises is located), that the End User must be given access to their metering installation. eg in a block of factories, the meters for all factories may be installed in a common service area and this area must be accessible for all factory owners/lessees. The term "End User's premises" better describes the requirement. Further the definition is somewhat ambiguous with respect to its exact usage. Is the Site the address of the premises? Or is the usage of Site Address more correct? Technical Requirements This needs a Glossary entry. Eg Metrology Procedure A Section 5.3 TI TNI Code This needs a Glossary entry Transmission Node Identity: A four character alpha-numeric code used to identify a virtual transmission node. Should be Identifier not Identity. Procedure Consultation - Participant Response Pack Page 11 of 197

12 Procedure Consultation - Participant Response Pack Page 12 of 197

13 2. Meter Data File Format Clause Heading Participant Comments Metering Competition Embedded Networks Meter Replacement Processes 1 INTRODUCTION 1.1 Purpose and Scope 1.2 Definitions and Interpretation 1.3 Related Documents 2 GENERAL RULES AND INFORMATION 3 TECHNICAL INFORMATION 3.1 Version details 3.2 File delivery To - The MSATS Participant ID of the intended Registered Participant, MP, MDP, LNSP. Procedure Consultation - Participant Response Pack Page 13 of 197

14 AusNet Services believe that the ENM needs to be added here; also the LNSP is a Registered Participant so there isn t a need to call them out separately. Make it consistent with 4.2 and File construction Mandatory and Required data The key to the initials used in the Field Requirement column of all Record data tables in sections 5 and 6 AusNet Services believe these references are incorrect and should be 4 and 5 4 INTERVAL METER READING FILE SPECIFICATION AND VALIDATION (NEM12) 4.1 Blocking cycle Refer to Appendix F for details of the blocking cycle for this file. AusNet Services believe the reference is incorrect and should be Appendix G Procedure Consultation - Participant Response Pack Page 14 of 197

15 4.2 Header record (100) Faceplate serial number as per NMI Standing Data for MSATS. This should be the old new Meter Serial number ID on the IntervalDate when the meter is replaced. Therefore, the recipient of this information should not dispute the validity of the configuration for interval metering data provided on a meter change date. 4.3 NMI data details record (200) AusNet Services believe that the statement should be made clearer by incorporating some text around the old meter serial id. This is important because Participants sometimes generate PMDs and VMDs based on whether their systems determine the meter serial number is correct or not. Suggested text: Faceplate serial number as per NMI Standing Data for MSATS. This should be the old Meter Serial number ID for IntervalDate prior to the meter replacement and the new Meter Serial number ID on the IntervalDate when Procedure Consultation - Participant Response Pack Page 15 of 197

16 the meter is replaced. AusNet Services also believe the deleted text should remain as it provides clarity for the Retailers that there will be discrepancies between MSATS and the MDFF. The removal of this will increase dispute of network bills. The Next Scheduled Reading Date NSRD provided in this file is accurate at the time the file is generated (noting this may be subject to change e.g. if route change etc.). MSATS is the database of record, therefore, should there be a discrepancy between the Next Scheduled Reading Date NSRD in this file, MSATS shall prevail. AusNet Services believe that for consistency, as the NSRD is a defined term in the glossary there isn t a need for it to be expanded in this section. 4.4 Interval data record (300) The latest date/time that any updated IntervalValue or QualityMethod for the IntervalDate. This is the MDP s version date/time that the metering data was created or changed. This date and time Procedure Consultation - Participant Response Pack Page 16 of 197

17 applies to data in this 300 record. Where all intervals for an IntervalDate are forward estimates, the time component of this field must be "00:00:01. When only parts of the day are forward estimates, this field is the latest date/time of the intervals that are not forward estimates AusNet Services believes the deleted statement should be left in as is provides guidance for new MDP s on the treatment of the time component for forward estimates. This is important because some participants may have built validations around this and it may cause issues for new MDP s as existing participants are not going to change their systems to accept other time components. This is the date/time stamp the MSATS system returns recording when metering data was loaded into MSATS. This date is in the acknowledgement notification sent to the MDP by MSATS. AusNet Services believes highlighted word should be records not recording. Procedure Consultation - Participant Response Pack Page 17 of 197

18 4.5 Interval event record (400) 4.6 B2B details record (500) 4.7 End of data (900) 5 BASIC METER READING FILE SPECIFICATION AND VALIDATION (NEM13) AusNet Services believe there should be consistency in the document so the heading of 5 should be changed to Accumulation, the diagram in 5.1 should be updated with accumulation and 5.3 heading should be Accumulation to match the changes in the definition for record indicator or this definition should be left as basic. 5.1 Blocking cycle 5.2 Header record (100) 5.3 Basic meter data record (250) A forward Eestimate cannot be provided in the PreviousRegisterRead field. AusNet Services believe this should Procedure Consultation - Participant Response Pack Page 18 of 197

19 read: An Estimate. The date/time the transaction occurred or, for a Substitution (quality flag = S or F ), when the reading eventmeter Reading should have happenedoccurred. AusNet Services believe the highlighted the should have been left in. The Next Scheduled Reading Date NSRD provided in this file is accurate at the time the file is generated (noting this may be subject to change e.g. if route change etc.). MSATS is the database of record, therefore, should there be a discrepancy between the Next Scheduled Reading Date NSRD in this file, MSATS shall prevail. AusNet Services believe that for consistency, as the NSRD is a defined term in the glossary there isn t a need for it to be expanded in this section. This is the date/time stamp the MSATS system returns recording when metering data was loaded into MSATS. Procedure Consultation - Participant Response Pack Page 19 of 197

20 This date is in the acknowledgement notification sent to the MDP by MSATS. AusNet Services believes highlighted word should be records not recording 5.4 B2B details record (550) 5.5 End of data (900) APPENDIX A TRANSACTION CODES FLAGS APPENDIX B FORMAT & UNIT OF MEASURE FIELD DETAILS APPENDIX C QUALITY FLAGS APPENDIX D METHOD FLAGS APPENDIX E REASON CODES APPENDIX OBSOLETE REASON CODES (ONLY TO BE USED WHEN Procedure Consultation - Participant Response Pack Page 20 of 197

21 F PROVIDING HISTORICAL DATA) APPENDIX G SUMMARY OF FILE FORMAT AND BLOCKING APPENDIX H EXAMPLE INTERVAL DATA FILE (NEM12) H.1 Actual interval - Remote read meter 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 H.6 Metering data for meter AusNet Services believes this example Procedure Consultation - Participant Response Pack Page 21 of 197

22 change with configuration change type 5 is incorrect as it does not reflect the changes of the new Meter Serial ID appearing in the file on the day of replacement. H.7 Transfer occurs on the NSRD for type 5 meter H.8 Meter change: type 6 to type 5 AusNet Services believes this example is incorrect as it does not reflect the changes of the new Meter Serial ID appearing in the file on the day of replacement. APPENDIX I EXAMPLE CONSUMPTION DATA FILE (NEM13) I.1 Actual read values I.2 Normal meter read with Estimate I.3 Meter read and meter change I.4 Historical Data values Procedure Consultation - Participant Response Pack Page 22 of 197

23 I.5 Transfer read APPENDIX J EXAMPLE OF USE OF THE REGISTER READ FIELDS Procedure Consultation - Participant Response Pack Page 23 of 197

24 3. Metrology Procedure: Part A Clause Heading General Participant Comments Metering Competition There are a significant number of drafting issues associated with the Jurisdictional Difference tables. Some of these issues are due to revised or new terms and definition and some are fundamentally out of step with the new Metering Contestability regime. AusNet Services understands that the Jurisdictions have been invited by AEMO to revise these on the basis of the new NER drafting and to cover the impacts of Metering Contestability. We also understand that changes to the Jurisdictional Difference tables have not been provided. On the basis of this understanding and on the further understanding that AEMO cannot change these table without Jurisdictional direction, AusNet Services has provided only limited comment on these Jurisdictional Difference tables. However we consider that these must be revised for the new regime to be rigorously defined and supported by the MEP. General The convention used in the Metrology Procedure and other Procedures since their inception of numbering each paragraph/sub-clause has many advantages. It provides the basis of cross referencing within the document and also when referring to particular requirements in other documents and in discussion. It is particularly useful to when major rewrites are being undertaken. It is the approach used by the AEMC in their Rules documents. To remove this very useful feature at this point in time is a major step backward. AusNet Services recommend that the next version move back to the practice used in the current Procedures. 1 INTRODUCTION Procedure Consultation - Participant Response Pack Page 24 of 197

25 1.1 Purpose and Scope 1.1 Purpose and Scope Current proposed wording: 1.1. Purpose and Scope emergency priority procedures, which AEMO is required to publish clause 7.8.5(b) of the NER; Should read "is required to publish under clause 7.8.5(b) of the NER" Current proposed wording: This Procedure has effect only for the purposes set out in the NER. The NER and the National Electricity Law prevail over this Procedure to the extent of any inconsistency. This is not required in the Procedures but rather appears to be covered in the Glossary and Framework. Scope The metrology procedure provides information on the application of metering installations to connection points. In particular, the metrology procedure sets out provisions for metering installations and metering data services relating to: 1.1 Purpose and Scope The Tracking Register gives no reason for the deletion of this Section (1.3) of the current Metrology Procedure (MEP). Whilst the Glossary and Framework provides a brief description of the coverage of the MEP and the SLPs, unlike the wording in this Section the Framework Document does not provide the basis of the split between the MEP and the SLP. If this Section is to be removed then the Framework Document needs to be expanded to provide the basis of MEP/SLP differentiation. 1.2 Definitions and Interpretation 1.3 Related Documents Procedure Consultation - Participant Response Pack Page 25 of 197

26 2.2. Meter provision and metering data provision process diagrams Current proposed wording: Any dispute arising out of the subject matter of this Procedure will be addressed using the dispute resolution process in clause 8.2 of the NER. AusNet Services consider that the diagrams in current Section 2.2 are a very helpful feature of the metrology framework and should be retained in on the metrology Procedures. Although the differentiation of the relative coverage of the MEP and the SLPs are unclear, it t would be our view that they be updated and retained in the MEP. The clause being replaced here current reads: The RP involved in a dispute of the kind referred to in clause must keep all records in relation to the dispute for a period of seven years from the resolution of the dispute. The kind of dispute referred to in Cl is one involving "records of the amount of electricity supplied to a metering point". 2 DISPUTE RESOLUTION Hence: * the current reference to the kind of dispute should be retained * the obligation re keeping records for 7 years should be extended to the MP and the MDP. This is particularly the case, given that the MC has no obligation to keep metering data but rather relies on the MDP for this recording. Further it should be made clear here that the MC does not need to archive all metering data itself, but rather only all records after the dispute in declared under Cl RESPONSIBILITY FOR METER PROVISION Procedure Consultation - Participant Response Pack Page 26 of 197

27 3.1. Overall requirements MCs must use MPs to provide, install, routinely test and maintain the relevant components, characteristics and service requirements of the metering installation as specified in the NER and the metrology procedure, as appropriate. MCs are responsible for the design of a metering installation and warrant that the design complies with the components, characteristics and service requirements specified in the NER and this Procedure. 3.1 Overall requirements MCs must ensure the components have been selected, properly installed and initially tested by the MPs so that the metering installation satisfies the relevant accuracy and performance requirements in the NER and the metrology procedure. These three sub clauses (We cannot give reference numbers as these have not been incorporated in this revised version!!) by virtue of their different wording with respect to the MC actions imply three different types of actions: i) MCs must use MPs to provide... ii) MCs are responsible for the design of... iii) MCs must ensure the components have been... by the MPs so that... It is the AusNet Services view that rather than three different approaches implied by the three different wordings that there is rather one approach: the MC has the role and responsibility to ensure compliance hence the term used must be "ensure". The clause re "use of MPs" is superfluous as this is already their obligation under the Rules Overall requirements MCs must ensure the components have been selected, properly installed and initially tested by the MPs so that the metering installation satisfies the relevant accuracy and performance requirements in the NER and the metrology procedure. Although the split between the MEP and the SLP is not clearly defined in the Framework document it would appear that the SLP would have a role and should be added to this clause. Procedure Consultation - Participant Response Pack Page 27 of 197

28 4. METERING INSTALLATION COMPONENTS 4 METERING INSTALLATION COMPONENTS The components, their characteristics, and associated service requirements for metering installations that have not been detailed in the NER have been itemised in this section. These words must be rewritten to be clear obligation: Something like: Metering installations must have in addition to the components identified with the NER Section 7.8.2, the components as detailed in this Section Requirement under National Measurement Act and use of Standards Current proposed words: New CTs for type 1, 2, 3, 4, 5 and 6 metering installations must meet the relevant requirements of AS and must also comply with any applicable specifications or guidelines specified by the National Measurement Institute under the National Measurement Act. New VTs for type 1, 2, 3, 4,5 and 6 metering installations must meet the relevant requirements of AS , AS , AS and AS 1243 and must also comply with any applicable specifications or guidelines (including transitional arrangements) specified by the National Measurement Institute under the National Measurement Act. Use of the term "new" in these clauses implies that different standards can be applied to components which are not "new". That is that there could be components in service or in stock which were legitimately purchased to standards specified at the time but which do not meet these requirements for new components. However Section 4.6 of this redrafted MEP includes grandfathering which applies to components from before 2008 but there is nothing re the grandfathering of components which have been purchased after 2008 but which do not meet the current requirements in these clauses. The situation re these should be made clear. Procedure Consultation - Participant Response Pack Page 28 of 197

29 4.1 Requirement under National Measurement Act and use of Standards The MC must ensure that a visible display is provided to display, at a minimum, the cumulative total energy for each Datastream measured by that metering installation. This phrase is superfluous. It is already stated that the MC must ensure that the MI meets all requirements. Hence for example they must ensure the requirements in the three clauses above apply but this is NOT stated in these clauses. Hence remove reference to MC must ensure in this clause. 4.1 Requirement under National Measurement Act and use of Standards Any programmable settings available within the metering installation, or any peripheral device that might affect the resolution of displayed or stored data must meet the relevant requirements of AS , AS and AS and must comply with any applicable specifications or guidelines specified by the National Measurement Institute under the National Measurement Act. Not sure whether this clause is required. The Aust Standards quoted are the same as those in the first clause of this Section 4.1 and hence settings are presumably already covered. If the clause is to be retained then: If a peripheral device affects the data then it must by definition be part of the metering installation. Delete this phrase. Move clause under the first clause of this Section 4.1 which also deals with meters. 4.2 Use of optical ports and pulse outputs * Note also "might affect" is unnecessarily vague - it either affects the data or it doesn't. Delete "might". The MC must provide pulse output facilities representing the quantity of electricity measured in accordance with the relevant Australian Standard for that meter within a reasonable time of being requested by a FRMP to provide such facilities. The MC is not going to "provide" the pulse output facilities but rather the obligation should be: The MC must ensure that pulse output facilities are provided that... Procedure Consultation - Participant Response Pack Page 29 of 197

30 4.2 Use of optical ports and pulse outputs A type 4A or 5 metering installation must have an optical port that meets the AS or AS or a computer serial port to facilitate downloading of 90 days of interval energy data for each meter associated with the metering installation in 35 seconds or less. A sub heading of "Optical Port" should be inserted above this clause consistent with the subheading for "Pulse Outputs". 4.2 Use of optical ports and pulse outputs Where the metering installation includes equipment for load control or the measurement of reactive energy, the installation and operation of that equipment will be governed by an instrument other than the metrology procedure, for example, a use of system agreement between the Local Network Service Provider and the financially responsible Market Participant. In the Tracking Register this clause is notated as included in the Network Devices Section (Section 12). But this is NOT included in that new Section. With respect to reactive measurement we cannot understand why this would require special mention outside the metrology requirement to provide these readings as required. 4.3 Password allocation 4.3. Password Allocation The MP must allocate read-only passwords to FRMPs, LNSPs and AEMO, except where separate read-only and write passwords are not available, in which case the MP must allocate a password to AEMO and the MDP only. It is unclear to AusNet Services why this refers specifically to an MP obligation rather than use the more usual and more correct "the MC must ensure..." 4.4 x values calculation and use Connection points must not be aggregated when calculating x. The proposed wording does not match the actual action. x is not calculated, but rather x is allocated based on the annual consumption compared with the volume threshold. This should rather read "Connection points must not be aggregated when determining the annual consumption or the Average Daily Load as the basis of the comparison with the volume threshold for "x"." Procedure Consultation - Participant Response Pack Page 30 of 197

31 4.5 y values calculation and use The proposed wording is: 4.6 Grandfathering Meters and components for a type 5 or 6 metering installation, which were installed, or which were held in stock for the MC prior to the following dates,: Previously the wording referred to the responsible person rather than the MC. It is AusNet Services view that the reference to the responsible person should be retained as this was the party involved at the time. The proposed wording is: Metering installations which that have been installed, or which are held in stock for the MC in a Jurisdiction, prior to the effective date of that jurisdiction s initial metrology procedure and Grandfathering This should read: 4.7 Data storage requirements for meters Metering installations which that have been installed, or which were held in stock for the responsible person in a specific Jurisdiction, prior to the effective date of that Jurisdiction s [lead cap] initial metrology procedure and Data Storage Requirements for Meters A type 4A or 5 metering installation must have the capability of storing interval energy data for a period of 200 days. Components of a type 5 metering installation installed or held in store for the responsible person prior to 1 January 2007 must have the capability of storing interval energy data for a period of at least two meter reading cycles plus 15 days, or 35 days, whichever is the greater. Why has this been removed? Meters held in stock by the RP prior to 1 Jan 2007 (and now in service) should continue to be grandfathered. 4.8 Meters and clocks Procedure Consultation - Participant Response Pack Page 31 of 197

32 The NER already defines trading interval : A 30 minute period ending on the hour (EST) or on the half hour and, where identified by a time, means the 30 minute period ending at that time. interval energy data The data that results from the measurement of the flow of electricity in a power conductor where the data is prepared and recorded by the metering installation in intervals which correspond to a trading interval or are submultiples of a trading interval. 4.9 Interval Meters The definition in the metrology procedure therefore needs only to define the basis of submultiples of a trading interval Suggest wording should be: Where a metering installation records interval energy data and the interval periods are based on parts of a trading interval ["TI" is NOT defined in the Glossary]: The end of each interval for a 15- minute interval period must be on the hour, on the half- hour and on each quarter of an hour (EST). Other sub-multiple intervals, where agreed with AEMO, the LNSP and the relevant Market Participant, provided that the ends of the intervals correspond each and every exact hour (EST) and half- hour (EST). Procedure Consultation - Participant Response Pack Page 32 of 197

33 The services set out in the minimum services specification apply to the capability of the metering installation itself. A metering installation is defined as: 5 MINIMUM SERVICES SPECIFICATION metering installation The assembly of components including the instrument transformer, if any, measurement element(s) and processes, if any, recording and display equipment, communications interface, if any, that are controlled for the purpose of metrology and which lie between the metering point(s) and the point at or near the metering point(s) where the energy data is made available for collection. Hence the concept of this additional clause appears flawed and superfluous as the definition limits the extent of the obligation to the components of the MI ie at the site only. AusNet Services consider that limiting the applicability of these Minimum Service Levels to the Metering Installation is not consistent with either the intent or the wording of Cl of the Rules. We consider that it is clear that the desired outcome is to define the minimum capability that the end to end facilities that an MC, in offering to provide a Minimum Service Specification service, must have in place. 5.1 Minimum Service Levels Whilst the wording of this Rules clause could have been clearer, the interpretation that the Minimum Service Levels only apply to the MI leaves a significant gap in the regulatory framework for smart meter services and fails to support a fundamental outcome of the Metering Contestability regime of facilitating access to quality advance meter services by Distributors and third parties. To interpret Cl in the way proposed is a barrier to this outcome. AusNet Services consider that an AEMO / industry-iec effort is required to define these end to end service levels. These could then be specified in another Procedure or added to the MEP in a second release. However despite the above being the AusNet Services view we have also made comment on the proposed MI service levels drafting proposed by AEMO. Procedure Consultation - Participant Response Pack Page 33 of 197

34 5.1. Minimum Service Levels The minimum service levels are made up of two elements: service availability and completion timeframes. 5.1 Minimum Service Levels To be consistent with the broad intent and drafting approach of the MEP this section should be rewritten as clear requirements/obligations: Rewrite as below or similar: A small customer metering installation must meet the minimum service specification in accordance with the two elements of the Minimum Service Levels [this should be in the Glossary as a defined term]: service availability and completion timeframe. 5.1 Minimum Service Levels Service Availability Except for periods of a lack of supply, metering installations must be capable of meeting the minimum services specification at all times. "lack of supply" is not a very precise term. This clause should cover more than a distribution network outage which could be implied from the proposed drafting. This should rather read: "Except for periods where mains supply is not available at the meter terminals..." Procedure Consultation - Participant Response Pack Page 34 of 197

35 Completion Timeframes The completion timeframes for each service are detailed in Table 5.1. They will be measured from the time a request is received by the metering installation to the time of completion of the relevant service by the metering installation. This should be rewritten: as a clear requirement/obligation with clarity of the service outcome measure Suggested revised wording: 5.1 Minimum Service Levels A small customer metering installation must meet completion timeframe [singular] for each MSS service as detailed in Table 5.1. Completion timeframes are measured: from the time a request is received by the metering installation to the time that the notification of completion of the relevant service by the metering installation appears at the communication interface at or near the metering point(s) where the notification of completion is made available for collection. A number of MSS services are not delivered immediately but rather the meter is requested to deliver the service at a point in time or to a requested schedule. Hence the completion timeframe must be measured to the availability of the notification of completion. Proposed wording is taken from the definition of Metering Installation in Chapter 10. [Note this Rules definition should be revised for the Metrology Procedure as the metering installation is now providing more than "metrology" outcomes] Procedure Consultation - Participant Response Pack Page 35 of 197

36 5.2. Completion Rates The completion rates for each service are detailed in Table The MC must be able to provide evidence demonstrating that small customer metering installations are capable of performing to the completion rates, upon request by AEMO. This should be rewritten as a clear requirement/obligation. A small customer metering installation must meet completion rates for each service as detailed in Table Completion Rates The wording: The MC must be able to provide evidence demonstrating that small customer metering installations are capable of performing to the completion rates, upon request by AEMO. should be deleted. The MC and their service providers must be able to demonstrate that they meet all the requirements of the metrology procedure and hence to single out this requirement is superfluous, and could be taken to indicate that other capabilities do not need to be demonstrated on request. Procedure Consultation - Participant Response Pack Page 36 of 197

37 5.3. Technical Requirements There are two technical requirements: 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. Where a poly-phase metering device is installed within a metering installation, the metering installation must be capable of recording and providing the average voltage and current over a nominated trading interval for one or more nominated trading intervals, for each connected phase. 5.1 Minimum Service Levels To be consistent with the broad intent and drafting approach of the metrology procedure this section should be rewritten as clear requirements/obligations: Rewrite as below or similar: A small customer metering installation must comply with the following technical requirements: be capable of measuring active power (Wh) and leading and lagging reactive power (VArh) for both import and export energy flows. etc, etc Procedure Consultation - Participant Response Pack Page 37 of 197

38 Although "Technical Requirements" are not defined in the NER nor in this metrology procedure [and AusNet Services consider that this is a necessary addition to the Glossary], we consider that these are capabilities of the meter which must be specified in a purchased meter to enable it to reasonably support the envisaged outputs required for smart meter services. We are unclear what Technical Requirements would require to be specified in the metrology procedure compared to those to be specified in a revised Australian Standard for meters. What is the basis of the distinction as understood by AEMO? However at least in the shorter term the metrology procedure is the ONLY place where these Technical Requirements can be specified, as we understand that the Australian Standard will not be in place and enforceable as the basis of meter designs and purchases until well after the start of Metering Contestability. AusNet Services consider that the Technical Requirements on this basis must include: 5.1 Minimum Service Levels auto-disconnection for a remote re-energisation of an installation with current flowing above settable limits and time periods as specified in the Victorian AMI Specification or similar. This is an essential safety feature and must be within the meters capabilities ie it is a Technical Requirement. meter internal temperature alarms which Victorian experience has shown to be essential to the prevention of meter fires with potential Health and Safety implications capability for routine delivery of power quality data (volts, amps etc as specified in the Minimum Service Specification meter enquiry service. The routine delivery of power quality data was a clear requirement identified in the AEMO advice to COAG re the services from smart meters. It is the AusNet Services view that this must be a capability built into the meter. The capability of the meter to measure the power quality data parameters and to store a single snapshot set is not sufficient capability to delivery routinely a set of power quality data frequently measured and stored throughout a day. there may be others which need to be included? Procedure Consultation - Participant Response Pack Page 38 of 197

39 Table 5.1 Minimum Service Levels and Minimum Standards Completion Timeframe 5.1 Minimum Service Levels AusNet Services are disappointed that AEMO has provided no assessment nor analytical basis for the Completion Timeframes in this Table. Whilst AusNet Services do not have firm suggestions for this measure, we are concerned that the "processing" time within the meter/mi is proposed to be so long. As AusNet suggested elsewhere it is the end-to-end time for the service delivery which governs the usefulness of the service to the industry. The industry have raised the need for "near real time access" to some services and on this basis have suggested that the transaction handling times in the updated e-hub should be less than 10 seconds. Whilst AusNet Services are unclear what is the basis of this proposed handling time and consider that further analysis and "justification" is necessary before this could endorse this as an e-hub requirement, it would appear to be inconsistent to have one part of the end-to-end service path being specified as less than 20 seconds but allow within the metrology procedure for the meter response time to be more than 5x's this duration. AusNet Services consider that this time should be significantly reduced based on a proper technical analysis of meter capabilities. Procedure Consultation - Participant Response Pack Page 39 of 197

40 Table 5.1 Minimum Service Levels and Minimum Standards Completion Rate AusNet Services are disappointed that AEMO has provided no assessment nor analytical basis for the Completion Rates in this Table, nor a clear definition of the measure. 5.1 Minimum Service Levels The stated requirement is that the meter responds in the Completion Timeframe for 99.5% of service requests. And hence conversely does not respond in the specified Completion Timeframe in 0.5% of requests. That is for 1 in 200 requests the Timeframe is longer. Or over a 12 month period of somewhat regular service requests, almost two days of service requests are not processed in the meter in the desired timeframe. This would appear to be rather poor performance from what is essentially a relatively simple electronic device presumably specifically designed for reliability and high availability. Does AEMO have analysis which supports this as the best possible outcome that can reasonably be delivered by advanced meters?? AusNet Services consider that this completion rate measure should be subject to a proper technical analysis of meter capabilities with the aim of validating that this can be significantly improved. Procedure Consultation - Participant Response Pack Page 40 of 197

41 Table 5.1 Minimum Service Levels and Minimum Standards Completion Timeframe for Remote Scheduled Meter Read Completed within 1 minute of the command being received by the metering installation As stated in the AusNet Services comments on the Completion timeframe definition, the outcome action for each of the services must be clear. This is particularly evident with respect to setting up a scheduled read service. 5.1 Minimum Service Levels The requester is wanting the MC/MP/MDP to establish a meter reading schedule to enable the delivery of metering data to the requester s requirements. The required outcome at the meter is to establish the correct schedule to support the requester's metering data requirements. Hence the desired Completion Timeframe for this service could be relatively long as the time delay for establishing the read schedule is not particularly critical. Each of the completion timeframes should be considered against the business requirements for that service. A blanket 1 minute is too long for some time critical services and potentially to short for services where timing is not critical. 6 SUMMATION METERING 7 EMBEDDED NETWORKS 8 REVERSION OF METERING INSTALLATION TYPES Procedure Consultation - Participant Response Pack Page 41 of 197

42 9 9 ROUTINE TESTING AND INSPECTION OF METERING INSTALLATIONS ROUTINE TESTING AND INSPECTION OF METERING INSTALLATIONS 9. ROUTINE TESTING AND INSPECTION OF METERING INSTALLATIONS Unless the MC has an Asset Management Strategy, metering installations must be tested and inspected in accordance with clauses 7.9 and S7.6 of the NER. Section 9 specifies AEMO s requirements in respect of a proposed asset management strategy that an MC will need to take into consideration when seeking approval of an Asset Management Strategy Reference to the Rules requirements for AEMO guidelines would be better wording: Suggested wording: Unless the MC has an Asset Management Strategy, metering installations must be tested and inspected in accordance with clauses 7.9 and S7.6 of the NER. Section 9 are the AEMO guidelines as required under NER clause S7.6.1 for the development of an Asset Management Strategy.. This clause currently states: For those meters for which new or amended pattern approval has been received from the National Measurement Institute or, in the absence of pattern approval, new or amended type testing has been undertaken by a NATA accredited laboratory or a body recognised by NATA under the ILAC mutual recognition scheme, the MC must ensure that the Sample Test Plan stipulates that this population of meter is tested at least once in the first three years of being placed in service. AusNet Services view is the Sample Test Plan requirement should not just apply to meters for which new or amended pattern approval has been received from the National Measurement Institute or, in the absence of pattern approval, new or amended type testing has been undertaken by a NATA accredited laboratory or a body recognised by NATA under the ILAC mutual recognition scheme as specified in the first part of this clause but rather apply to ALL meters. Further the Australian Standard re Sample Testing of Meters requires the first sample test to be carried in the second or third years of service (not in the first year) and the wording should reflect this requirement. Procedure Consultation - Participant Response Pack Page 42 of 197