METERING COMPETITION EMBEDDED NETWORKS METER REPLACEMENT PROCESSES PROCEDURE CONSULTATION PARTICIPANT RESPONSE PACK. Participant: United Energy

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1 UNITED ENERGY METERING COMPETITION EMBEDDED NETWORKS METER REPLACEMENT PROCESSES PROCEDURE CONSULTATION PARTICIPANT RESPONSE PACK Participant: United Energy Completion Date: 31 May 2016

2 3. Metrology Procedure: Part A AEMO advised in the POC information position paper that Victorian AMI meters would remain as type 5 meters, however this is extremely unclear across the metering documentation and some positive statement is required in formal rules consultation processes on this matter. AEMO should make this clear in the Grandfathering clause in NMP Part A. If the alternative is intended then which NER clauses requires an already registered meter in the market to be reclassified as a different meter type? There are a number of jurisdictional metrology tables which need updating to cater for the NER as at 1 Dec 2017 to reflect the new meter terminology. AEMO have made some small changes in the Victorian material but have left old clause references and terminology. When will these be addressed fully in a consultation process so there is a final metrology procedure available for use in internal design/build processes? The connection processes across the new metering and coordinating parties is not clear in the NMP or SLPs. These more complex processes to connect customers and supply meters need to be clear, without industry agreed build packs, these procedures will not provide a robust framework for consistent industry transactions. It is important that retail market procedures and B2B procedures are finalised as soon as possible to allow industry to build and test. The metrology and exemption process for type 4A, metrology for Vic AMI type 5 and the issues around type 4 and type 5 accreditation and metrology processes need to be clarified in these NMP or SLP documents. Participant Comments Clause Heading Metering Competition Embedded Networks Meter Replacement Processes 1 INTRODUCTION 1.1 Purpose and Scope UE recommend that the type 4a exemption process also be included in this document rather than create more documents. 1.2 Definitions and Interpretation Several inconsistencies were noted between the NMP and the Glossary which should be clarified. The term Metering Data Alarm is used in the doc, but the glossary calls out Meter Alarm The term Meter Serial Number is used in the doc, but the glossary calls out Meter Serial ID NB Data stream in the glossary is datastream rather than Data Stream. 1.3 Related Documents 2 DISPUTE RESOLUTION

3 3 RESPONSIBILITY FOR METER PROVISION An MC must ensure that a metering installation and its components are properly installed and initially tested however the drafting in 3.1 on overall responsibilities does not make the MC responsible under the NER for ongoing compliance. Suggest drafting be amended. 3.1 Overall requirements 4 METERING INSTALLATION COMPONENTS 4.1 Requirement under National Measurement Act and use of Standards A Victorian Jurisdiction variation is required here to clarify that the Type VICAMI as mentioned in the AEMO Power of Choice Information paper (p7) is to remain as a Type 5 for metrology purposes (but with Remote Reading capability). This needs to be clear throughout the metering documentation. Last para should the stored data be referring to meter data and time standards and not other measurements voltage, DLC etc? 4.2 Use of optical ports and pulse outputs Pulse outputs are not part of the Vic. Min. Spec. At the moment this clause says the MC must provide pulse outputs on request. We cannot comply, a grandfathering clause needs to be included. 4.3 Password allocation Once again not able to comply with our AMI system. We cannot provide passwords for direct access to meters, the drafting should be limited to types 1-4 installed pre 1 Dec Passwords allocation and security concerns are becoming more sophisticated and password will be digital rolling passwords, the concepts of sharing these with other parties on an ongoing basis is impractical. 4.4 x values calculation and use 4.5 y values calculation and use 4.6 Grandfathering This should also describe Vic AMI meters i.e. Vic AMI meters installed prior to 1 Dec 2017 will be deemed to be compliant with Metrology Procedures and other NEM procedures and be able to remain type 5 meters. No new Vic AMI meters will be able to be installed by Victorian distributors as a regulated metering service. When a meter fails and the site becomes contestable, the meter must be replaced with a compliant meter by the new MC. 4.7 Data storage requirements for meters 4.8 Meters and clocks Query the reference ?

4 4.9 Interval Meters TI, trading interval needs to be defined in the glossary. 5 MINIMUM SERVICES SPECIFICATION Suggest redrafting as the first sentence is confusing. Where a small customer metering installation needs a meter exchange after 1 Dec 2017 or for a new connection on small customer after 1 Dec 2017, the metering installation must have the capability to deliver the services in Schedule 7.5 NER. Subject to the telecommunications being available or a customer refusing telecommunications and remote read capability the metering installation has the capability to deliver the minimum services. Large customers could also utilise these minimum services capabilities and Victorian AMI meters may meet some of these requirements. The intent of the drafting should be clearer. 5.1 Minimum Service Levels 5.2 Completion Rates We note that the service levels here pertain only to the meter, which doesn t actually achieve the industry outcomes of near real-time end to end metering services. 5.3 Technical Requirements The complete SLAs for Advanced Metering Services (which we assume to be part of the SMP) should highlight the end to end service level obligations. Recommend that remote reconnection has an auto disconnect function where a reconnection occurs and load is on above a certain threshold. As AEMO mentioned the Australian Standard process might address this safety issue but this is unlikely to occur in time for 1 Dec 2017 commencement. If AEMO is not able to take on board safety matters then jurisdictional tables should be implemented for the Ministers to take a position in conjunction with the safety regulators. 6 SUMMATION METERING No context is provided here to explain summation metering. In other sections (see 4.9 Interval Meters), context is provided as to which circumstances these statements apply. Please add. 7 EMBEDDED NETWORKS The embedded network jurisdictional table for Victoria specifies an interval meter but not an interval meter that would ordinarily apply to that customer ie a type 4 min services spec meter or normal type 4 or 4A etc 8 REVERSION OF METERING INSTALLATION TYPES This section does not exclude scenarios where an existing Type 5 meter can be replaced with another Type 5 meter in Victoria, or a type 4/4a to type 5 or a VIC AMI type 5 to a type 5, 4a or 4 The jurisdictional metrology material needs to be more fully considered in light of meters already installed in Victoria. 9 ROUTINE TESTING AND INSPECTION OF METERING INSTALLATIONS

5 Insert text point b: Where the LNSP is required to install, upgrade or modify an electrical supply as part of a meter installation process, the LNSP will be entitled to open and reseal the terminal cover of meters installed by an MP for the purposes of testing the safety or integrity of an electricity supply. Retailers or LNSPs make a request for a certain type of metering, by using the term Market participant is the intent to enable an SGA or DRA to also request changes in metering? 10 INSTALLATION OF METER(S) The meter must not only measure electricity supplied but must also include energy exported or generated which may go to grid, this data may also be required for jurisdictional feed in tariffs. Suggest using terms like import and exported electricity. The 20 business day service level for MCs to replace a meter appears to be in contradiction with the SLP which specifies 10 business days, particularly where metering is malfunctioning. UE believes the implementation of an outbound meter faulty notification is required to formalise this notification to the Retailer where a new MC is to be appointed. The 20 business day obligation for a new MC to install a meter does not work when a faulty meter causes the customer to be off supply. The procedure needs to ensure that the new MC must be appointed and be prepared to respond in real time when they are made aware of a meter failure at a premise for which they are the current or new MC. Supply restoration obligations must not be placed on the LNSP where the customer is off supply whilst waiting for a new meter to be installed Installation by ASPs 11 METER CHURN The amendments are missing a requirement for pre-notification to the current MP. As meters move to remotely read meters, this will allow the current MP to understand that their meter is not working because it has been removed as opposed to sending resources to the field to correct the failed remote reads. This is particularly the case given that 11.3 (b) suggests that CATS will only provide the information in 11.3 (a) retrospectively. Suggest site be amended back to premise Who can Initiate a Meter Churn 11.2 Who can Perform the Meter Churn How is a Meter Churn to be Performed DE-COMMISSIONING AND REMOVAL OF METERING EQUIPMENT AND NETWORK DEVICES b) not possible to supply final meter reads within 2 business days of receiving a meter back from internal or external providers. Where a new MP is removing a network device, it also should be returned to the owner, LNSP. MPs should not be able to remove network devices (if they are legally allowed to touch network assets) and leave assets at site or elsewhere for the owner to find. Given that MP s appear to have a NER right to remove network devices in limited

6 circumstances, and meters, the MP will already be returning meters to the LNSP as old MP and can readily return network devices also without incurring additional costs. The NER (i) (2) requires the network device procedure to also deal with the return of the network device to the LNSP. The drafting needs to be amended to include a network device to also be returned to the LNSP within 10 business days. The procedure provides no methodology or process for the MC to contact the LNSP to agree the removal of a network prior to its removal. This is likely to therefore be informal and to the detriment of the LNSP, who will unnecessarily investigate network device faults. UE recommend that prior consent be required via a formal B2B notification. NER (i) (3) requires the network device procedure to develop and maintain the notifications for removal of the network device ie the prior consent notification of removal of a network device or as soon as practical after removal (a) must include the notification prior to the removal for consent and the form of the notification ie a B2B Procedures Service Orders (b) the network device can only be removed by the MC where the network device ONLY has a control or timeswitch that will be obsolete as a result of the meter churn as the new metering is providing the service. The network device can also be providing useful network operational data and may be integrated with backend network management systems relating to customers off supply. The drafting must be amended to include the word only in relation to the services, if there are other services and data being gained then the device itself is not obsolete Network Devices Section provides authorisation for the LNSP to break seals on an MCs meter as required to alter the metering installation for a network device, but this should be a broader statement which allows the LNSP to do the same if any testing is required e.g. if the MP installs the meter as part of a connection and the LNSP subsequently attends the site to connect & energise the site, the LNSP should be able to break the seals to perform any testing. This same concept needs to be included in the metering installation section 10, of the NMP Part A. We assume that UE as an accredited MP retains its accreditation as an MP for undertaking any metering installation works and requires no new accreditation under a new competitive framework if there is a need to test or alter seals on a type 4 minimum services meter or type 4 or 4A meter. Section specifies the notification that must be issued if a Network Device is installed without permission. This should also include a set of valid reasons for removal. If this is not provided, the LNSP may unnecessarily dispute the removal of a device. The drafting should note the timing obligation ie as soon as practical in accordance with the NER. As noted above the network device procedure needs to cover the notification (refer response to 12.1), the drafting should refer to a B2B Procedure Service Orders and the B2B procedures will need to be updated for the transaction notifications/consent etc between the MC and the LNSP or MC/MP and LNSP. Electronic format is too generic. This needs to be a standard notification transaction to the LNSP, as there may be many different MCs in operation i.e. it is not feasible to have an arrangement and varying notification method for possibly greater than 10 MCs Request for testing type 1 6 metering installations Unclear what clause this is referring to?

7 13 RESPONSIBILITY FOR METERING DATA SERVICES 13.1 Metering data services Why is the MC or the FRMP mentioned in the drafting? The MC must engage an MDP in NER not a FRMP. The jurisdictional metrology material will need updating to correct the references but also to make clear whether an accumulation boundary will apply to a manual read interval meter that is a 4A and treated like a type 5. The MC must ensure that data is collected from types 5 and 6 metering no more than 2 business days prior or 2 business days after the scheduled read date. This MC obligation should also extend to type 4A metering where there is a need to have a next scheduled read date. The drafting should be amended to include a 4A. The old 3.4.9A, which is VIC AMI jurisdictional metrology material to enable a type 5 Vic AMI meter to be read more frequently than next scheduled read date should be extended and the references corrected. We understand that this may occur sometime late in Metering data collection The establishment and agreement of a read cycle, old , should be reflected in the drafting. The MC needs to establish the read schedule and the meter read frequency and agree this with the FRMP and the LNSP for manually read meters. The only changes required to this clause are to change the responsible person to MC and to include the further manually read meter, type 4A in this agreement in addition to types 5/6. The read dates are the triggers for billing and also for meter data follow up when data is missing. Meters could be on monthly or quarterly reads and there is an expectation that these cycles would at least continue reflecting no backwards move in service or billing frequency in the market. The FRMP and the LNSP need to agree the read frequency. As it is currently drafted it appears like types 1-4 and Vic AMI meters which can be read daily and data provided daily could revert to data only being provided once every three months. If type 5 Vic AMI does not have a scheduled read date continued as all type 5 Vic AMIs are remotely read daily then the old 3.4.9A could also be removed and the jurisdictional metrology material for Vic on 13.4 and also NMP Part B, Metering data storage 13.4 Access to energy data and metering data 13.4 (a) access to metering data needs to be provided in accordance with the MDP SLP, why is this limited to type 1, 2, 3, and 4? Surely this applies to all meter types and should include 4A, 5 and 6? The VIC AMI jurisdictional metrology material to enable type 5 Vic AMI meters that are read more frequently to have the data provided more frequently should be extended and the references corrected. Where the Victorian service levels apply, if this is the case, beyond 1 Dec 2017, then the obligation should be drafted as a requirement. We understand that this may occur sometime late in 2016.

8 13.5 Verification of metering data for type 4A, 5, 6 and 7 metering installations The drafting needs to be reviewed and realigned to the old NMP clauses. The first two paragraphs relate to type 4A, 5 and 6 metering. The third para relates to all meter types. The references to type 7 metering installations need to be re-inserted in the 4th and 5th paragraphs Metering installation type 7 sample testing 13.7 Request for test of calculated metering data 13.8 AEMO s Metering Data Obligations 14 EMERGENCY PRIORITY PROCEDURES UE agree with AEMO this is not an easy matter for implementation in a newly created contestable market Criteria for determining Emergency Condition LNSPs are unlikely to negotiate individual service agreements with MCs regarding Emergency Management, as events such as load shedding are managed at Feeder level and would involve meters for multiple MCs. MC s may but are not obliged to have capability to offer such services or to offer the services on reasonable terms. Where an MC offered such services, their retailers/customers would have no or reduced loads and MCs who choose not to offer the services would have retailers/customers who remain on supply. In emergency situations all retailers or customers of retailers should be treated in a non-discriminatory manner, this may not be possible in this competitive model in relation to emergency, supply limitations and seeking to balance improved community services (maintain supply to essential services, traffic lights etc as opposed to dropping feeders) Disruption of power to one site would not appear to be a criterion for an emergency condition. Whilst risk of a fatality due to a live wire down is an emergency condition for the network, reliance on possible contracts for deenergisation within premises through the service agreement may not make safe a situation in the road. UE consider that the benefits of using optional capability in a piecemeal manner for an emergency situation is unlikely to be practical. An emergency event is not a scenario for financial or commercial. Commercial arrangements for the unimpeded use of MC remote de-energisation / re-energisation services may be arranged, in practice we think this will be difficult to manage. Note: the minimum service specification excludes load limiting which would have been beneficial as a capability gain on current Vic AMI meter specs Metering Installations Affected As noted in the drafting the impact on customers would be different where they have a manually read meter or old remotely read meter vs a smart meter. In an emergency this could mean that small customers are taken off

9 supply and business customers are able to remain on supply. Use of these new smart meter features needs careful consideration. Where an emergency condition exists, load can be shed and type 7 metering installations can be impacted, suggest the clause is removed Prioritisation of Services by Metering Coordinator in Emergency Condition If this process were adopted UE concur that disconnection and reconnection services should take priority. There was discussion in the AEMO workshops on the priorities of the MC in an emergency in relation to all other services eg daily meter reads etc on both impacted customers or other non-impacted jurisdictions and how this should be handled if there was an emergency in one location. The drafting should be improved is the LNSP prioritising the delivery of all services from the MC or just the services that are limited in the LNSP-MC agreement? The requirement in the NER (b) states that AEMO must establish and publish these emergency priority procedures and these procedures must include which services the MC must prioritise at the request of the LNSP. The drafting in this clause does not address the NER requirement Other Laws Prevail