metering competition embedded networks … · metering competition embedded networks meter...

METERING COMPETITIONEMBEDDED NETWORKSMETER REPLACEMENT PROCESSES

PROCEDURE CONSULTATIONPARTICIPANT RESPONSE PACK

Participant: AusNet Services (AST)

Completion Date: 31/05/2016

Table of Contents

1. Glossary and Framework.....................................................................................................................................3

2. Meter Data File Format .....................................................................................................................................13

3. Metrology Procedure: Part A.............................................................................................................................24

4. Metrology Procedure: Part B.............................................................................................................................59

5. MSATS Procedures: CATS Procedure Principles and Obligations......................................................................80

6. MSATS Procedures: MDM Procedures ............................................................................................................129

7. MSATS Procedures: Procedure for the Management of Wholesale, Interconnector, Generator and Sample(WIGS) NMIs ............................................................................................................................................................135

8. NEM RoLR Process Part A and B – MSATS Procedure: RoLR Procedures........................................................162

9. NMI Standing Data Schedule...........................................................................................................................171

10. Service Level Procedures for MDP ..............................................................................................................173

11. Service Level Procedures for MP.................................................................................................................188

12. Other Issues Related to Consultation Subject Matter.................................................................................197

Metering Competition – Embedded Networks – Meter Replacement Processes

Procedure Consultation - Participant Response Pack of 197

1. Glossary and Framework

Clause Heading

Participant CommentsMetering Competition

Chapter 1 Introduction

1.1 Purpose and Scope

1.2Definitions andInterpretation



1.2.1 Glossary

Capitalised words, phrases and abbreviations set out in Chapter 3 have the meanings set outopposite 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) havethe 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 secondparagraph:

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 thisdocument. have the meanings set out opposite them when used in this document and theRetail Electricity Market Procedures (except B2B Procedures).

1.2.2 Interpretation

1.3 Related Documents

Chapter 2 Framework



2.1The Role of the RetailMarket in the NEM

The physical production of electricity is carried out using various technologies and transportedthrough high voltage transmission lines to distribution networks that operate at low voltage anddeliver electricity to End Users at the required voltage.

In financial terms, Generators who produce electricity in the NEM are required to sell theiroutput 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 spotmarket and then sell it to End Userss.

FRC prevails throughout the NEM, which means that any End User can purchase electricityfrom a retailer of their choice. For this to work, however, it is necessary to have processes andsystems that facilitate an orderly transfer of End Users from one retailer to another, and toensure 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 theimpetus for the Retail Market Procedures. To provide a more complete description of therequirement for the Procedures, this Framework description should be expanded to includedistributor billing and network analysis.

Similarly the diagram should include the provision of metering data to the distributor datasystem and its support for network billing and network analysis.

Further the diagram shows retailer billing being driven from MSATS data whereas the MeteringData is the key input into the End Use Bills

2.2Retail Electricity MarketProcedures



2.2.1 Metrology Procedure

The descriptions of the Metrology Procedure and the SLPs should more clearly provide the keyranges of coverage of the NER Chapter 7, Metrology Procedure and the SLPs. It would aidmarket understanding and ensure clarity of document purpose if the relative content of each ofthese three “levels” of the metrology documentation was clearly specified.

Maybe a good approach to achieving this would be to include some description of the relativeroles and relationship of the MC and the MDP/MP.

2.2.2 B2B Procedures

2.2.3 MSATS Procedures

The MSATS Procedures are made under clause 7.16.2 of the NER and are divided into anumber of procedures, known as CATS, WIGS and MDM Procedures:

This listing should be expanded to include the other MSATS documents: NMI Standing Data,NMI Procedures etc

2.2.3.1 CATS Procedures

2.2.3.2 WIGS Procedures

2.2.3.3 MDM Procedures

2.2.4 RoLR Procedures

2.2.5Metering ServicesProcedures

2.2.5.1 Service Level Procedures



2.2.5.2 Meter Churn Procedures

Chapter 3 Glossary

AEMO System Administrator The AEMO person who creates the initial PA IDs for each Participant, with the PA Rightassigned to each.

“PA ID” and “PA Right” are not defined in this GlossaryBMP 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 italicsBusiness Group 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 therelationship and the differences between the companies [presumably with different ABNs??] inthe group.

CATS Standing Data Access 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

Child Name 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

Current RP 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 This needs a Glossary entry. Eg Metrology Procedure A Section 12.

Inventory Table A table of devices for unmetered loads associated with each NMI as described in sections14.3.3 and 14.4.3 of Metrology Procedure: Part B.Table references are incorrect as per drafted Met B procedures



Metering Alarm Any alarm situated within a metering installation designed to detect any unexpectedoccurrence, such as a loss of supply, VT or phase failure, tamper detection, reverse energyflow, pulse overflow, cycle redundancy check error and temperature or time tolerance.

Think the description needs to state relevant alarms.Metering Installation The NER defines metering installation as:

The assembly of components including the instrument transformer, if any, measurementelement(s) and processes, if any, recording and display equipment, communicationsinterface, if any, that are controlled for the purpose of metrology and which lie between themetering point(s) and the point at or near the metering point(s) where the energy data ismade available for collection.

It would appear that this definition is NOT satisfactory to define a metering installation which isproviding smart meter services. The outcomes are no longer just “for the purpose ofmetrology” but for the broader outcomes of smart meter services and the communicationsinterface is no longer where just “energy data is available for collection” but in fact where thebroader range of smart meter services are available for collection.

AusNet Services suggest that the Glossary should include a modification of the NER definitionwhich encompasses these broader services.

Meter StatusNo description

Suggest – the status of the meter in MSATS. Eg current (C) or removed (R)

Metering Data VerificationProcess

The process by which a Participant queries the metering data received from an MDP andprovide 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 tryingto achieve. The VMD process does not provide alternative metering data to an MDP for thepurpose of substituting.

Minimum Service Levels This needs a Glossary entry. Eg Metrology Procedure A Section 5.1.



MT PASA 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 itappear in for Retail markets? If it doesn’t appear in any of the documents remove it from theglossary.

NEM Retail OperationsContact List

No description

Contact list of relevant people in market participant businesses

Next Scheduled Read DateSee Table 4M of CATS procedures

Don’t think the description in the CATS procedures adequately describes the NSRD.

New MC This needs a Glossary entry

NMI Discovery Search 1

The process of finding a NMI and the NMI Checksum by searching MSATS using the Site, theDPID or a meter’s serial number. See also the NMI Search Rules in section 44.3 of the CATSProcedures


NMI Discovery Search 2

The process of finding a NMI and the NMI Checksum by searching MSATS using the Site, theDPID or a meter’s serial number. See also the NMI Search Rules in section 44.4 of the CATSProcedures


NMI Search Rules

See Table 44-B in the CATS Procedures. The search that is available in MSATS to enable aParticipant identify a NMI when the only information available is the DPID, the meter serialnumber or the Site address.


Parent Name Although a Glossary entry, no definition is provided.

Read Type Code Types of meter readings detailed in Table 4-L of the CATS Procedures




Registration 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.

Retrospective Change A change to a NMI that is to be effective on or before the date the Change Request issubmitted.

Retrospective is today or before.

Routine Testing For the purposes of the Metrology Procedure, includes the ongoing and regular maintenancetesting, compliance testing and in-service testing of a metering installation initiated by the RPor MP to fulfil their obligations under clause S7.3 of the NER.

Should say MC not RP

Service Provider An MDP, MP or LNSP.

AusNet Services are unsure where the term “Service provider” is used, however in our view itis most often used in market documentation and communications as the “group name” for theMPs and MDPs. Eg “the Service Providers appointed by the MC”.

Although the term Network Service Provider or LNSP is applied to Distributors, they are notgenerally grouped under the term Service Provider with the MDP and the MP. Although notrecommended, if used in the broader sense, then presumably ENMs would also be groupedunder the term.



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 oneinstance:

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 themetering installation via safe, convenient and unhindered access when it is not located at theSite.

However the use of the defined term "Site" rather the “premises” has taken away the intent ofthe 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 ofland) which was generally accessible by the End User ie not located at their premises, butlocated at the Site (ie at the address of the land on which their premises is located), that theEnd User must be given access to their metering installation. eg in a block of factories, themeters for all factories may be installed in a common service area and this area must beaccessible 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 theaddress 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 This needs a Glossary entry

TNI Code Transmission Node Identity: A four character alpha-numeric code used to identify a virtualtransmission node.

Should be Identifier not Identity.



2. Meter Data File Format

Clause HeadingParticipant Comments

Metering Competition Embedded Networks Meter ReplacementProcesses

1 INTRODUCTION


1.2 Definitions and Interpretation


2GENERAL RULES ANDINFORMATION

3 TECHNICAL INFORMATION

3.1 Version details

3.2 File deliveryTo - The MSATS ParticipantID of the intended RegisteredParticipant, MP, MDP, LNSP’.



AusNet Services believethat the ENM needs to beadded here; also the LNSPis a Registered Participantso there isn’t a need to callthem out separately.

Make it consistent with 4.2and 5.2

3.3 File construction

3.3.6 Mandatory and Required data

The key to the initials used in the FieldRequirement column of all Record datatables in sections 5 and 6

AusNet Services believe these referencesare incorrect and should be 4 and 5

4INTERVAL METER READINGFILE SPECIFICATION ANDVALIDATION (NEM12)

4.1 Blocking cycle

Refer to Appendix F for details of theblocking cycle for this file.

AusNet Services believe the referenceis incorrect and should be Appendix G



4.2 Header record (100)

4.3 NMI data details record (200)

Faceplate serial number as per NMIStanding Data for MSATS. This shouldbe the old new Meter Serial number IDon the IntervalDate when the meter isreplaced. Therefore, the recipient ofthis information should not dispute thevalidity of the configuration for intervalmetering data provided on a meterchange date.

AusNet Services believe that thestatement should be made clearer byincorporating some text around the oldmeter serial id. This is importantbecause Participants sometimesgenerate PMDs and VMDs based onwhether their systems determine themeter serial number is correct or not.

Suggested text:

Faceplate serial number as per NMIStanding Data for MSATS. This shouldbe the old Meter Serial number ID forIntervalDate prior to the meterreplacement and the new Meter Serialnumber ID on the IntervalDate when



the meter is replaced.

AusNet Services also believe thedeleted text should remain as itprovides clarity for the Retailers thatthere will be discrepancies betweenMSATS and the MDFF. The removal ofthis will increase dispute of networkbills.

The Next Scheduled Reading DateNSRD provided in this file is accurate atthe time the file is generated (notingthis may be subject to change e.g. ifroute change etc.). MSATS is thedatabase of record, therefore, shouldthere be a discrepancy between theNext Scheduled Reading Date NSRD inthis file, MSATS shall prevail.

AusNet Services believe that forconsistency, as the NSRD is a definedterm in the glossary there isn’t a needfor it to be expanded in this section.

4.4 Interval data record (300)

The latest date/time that any updatedIntervalValue or QualityMethod for theIntervalDate. This is the MDP’s versiondate/time that the metering data wascreated or changed. This date and time



applies to data in this 300 record.Where all intervals for an IntervalDateare forward estimates, the timecomponent of this field must be"00:00:01”. When only parts of the dayare forward estimates, this field is thelatest date/time of the intervals thatare not forward estimates

AusNet Services believes the deletedstatement should be left in as isprovides guidance for new MDP’s onthe treatment of the time componentfor forward estimates. This isimportant because some participantsmay have built validations around thisand it may cause issues for new MDP’sas existing participants are not going tochange their systems to accept othertime components.

This is the date/time stamp the MSATSsystem returns recording whenmetering data was loaded into MSATS.This date is in the acknowledgementnotification sent to the MDP by MSATS.

AusNet Services believes highlightedword should be records not recording.



4.5 Interval event record (400)

4.6 B2B details record (500)

4.7 End of data (900)

5BASIC METER READING FILESPECIFICATION ANDVALIDATION (NEM13)

AusNet Services believe there shouldbe consistency in the document so theheading of 5 should be changed toAccumulation, the diagram in 5.1should be updated with accumulationand 5.3 heading should beAccumulation to match the changes inthe definition for record indicator orthis 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 beprovided in the PreviousRegisterReadfield.

AusNet Services believe this should



read:

An Estimate…….

The date/time the transaction occurredor, for a Substitution (quality flag = “S’or “F”), when the reading eventMeterReading should havehappenedoccurred.

AusNet Services believe the highlightedthe should have been left in.

The Next Scheduled Reading DateNSRD provided in this file is accurate atthe time the file is generated (notingthis may be subject to change e.g. ifroute change etc.). MSATS is thedatabase of record, therefore, shouldthere be a discrepancy between theNext Scheduled Reading Date NSRD inthis file, MSATS shall prevail.

AusNet Services believe that forconsistency, as the NSRD is a definedterm in the glossary there isn’t a needfor it to be expanded in this section.

This is the date/time stamp the MSATSsystem returns recording whenmetering data was loaded into MSATS.



This date is in the acknowledgementnotification sent to the MDP by MSATS.

AusNet Services believes highlightedword should be records not recording

5.4 B2B details record (550)

5.5 End of data (900)

APPENDIXA

TRANSACTION CODES FLAGS

APPENDIXB

FORMAT & UNIT OF MEASUREFIELD DETAILS

APPENDIXC

QUALITY FLAGS

APPENDIXD

METHOD FLAGS

APPENDIXE

REASON CODES

APPENDIXOBSOLETE REASON CODES(ONLY TO BE USED WHEN



F PROVIDING HISTORICAL DATA)

APPENDIXG

SUMMARY OF FILE FORMATAND BLOCKING

APPENDIXH

EXAMPLE INTERVAL DATA FILE(NEM12)

H.1Actual interval - Remote readmeter

H.2Substituted interval - Remoteread meter

H.3 Interval data – type 5 Estimate

H.4Multiple NMIs and datastreams, remote read meter –(all actual data)

H.5

Remote interval data –MultipleQualityMethod/ReasonCodecombination

H.6 Metering data for meter AusNet Services believes this example



change with configurationchange – type 5

is incorrect as it does not reflect thechanges of the new Meter Serial IDappearing in the file on the day ofreplacement.

H.7Transfer occurs on the NSRDfor type 5 meter

H.8 Meter change: type 6 to type 5

AusNet Services believes this exampleis incorrect as it does not reflect thechanges of the new Meter Serial IDappearing in the file on the day ofreplacement.

APPENDIXI

EXAMPLE CONSUMPTIONDATA FILE (NEM13)

I.1 Actual read values

I.2Normal meter read withEstimate

I.3 Meter read and meter change

I.4 Historical Data values



I.5 Transfer read

APPENDIXJ

EXAMPLE OF USE OF THEREGISTER READ FIELDS



3. Metrology Procedure: Part A


Metering Competition

General

There are a significant number of drafting issues associated with the Jurisdictional Differencetables. Some of these issues are due to revised or new terms and definition and some arefundamentally out of step with the new Metering Contestability regime.

AusNet Services understands that the Jurisdictions have been invited by AEMO to revise theseon the basis of the new NER drafting and to cover the impacts of Metering Contestability. Wealso 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 changethese table without Jurisdictional direction, AusNet Services has provided only limited commenton these Jurisdictional Difference tables. However we consider that these must be revised forthe 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 ofnumbering each paragraph/sub-clause has many advantages. It provides the basis of crossreferencing within the document and also when referring to particular requirements in otherdocuments and in discussion. It is particularly useful to when major rewrites are beingundertaken. 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. AusNetServices recommend that the next version move back to the practice used in the currentProcedures.

1 INTRODUCTION




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"



This Procedure has effect only for the purposes set out in the NER. The NER and the NationalElectricity 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 andFramework.


ScopeThe metrology procedure provides information on the application of metering installations toconnection points. In particular, the metrology procedure sets out provisions for meteringinstallations and metering data services relating to:

The Tracking Register gives no reason for the deletion of this Section (1.3) of the currentMetrology Procedure (MEP). Whilst the Glossary and Framework provides a brief description ofthe coverage of the MEP and the SLPs, unlike the wording in this Section the FrameworkDocument 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 providethe basis of MEP/SLP differentiation.





2.2. Meter provision and metering data provision process diagrams


Any dispute arising out of the subject matter of this Procedure will be addressed using thedispute 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 ofthe metrology framework and should be retained in on the metrology Procedures. Although thedifferentiation of the relative coverage of the MEP and the SLPs are unclear, it t would be ourview that they be updated and retained in the MEP.

2 DISPUTE RESOLUTION

The clause being replaced here current reads:

The RP involved in a dispute of the kind referred to in clause 1.11.2 must keep all records inrelation to the dispute for a period of seven years from the resolution of the dispute.

The kind of dispute referred to in Cl 1.11.2 is one involving "records of the amount of electricitysupplied to a metering point".

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. Thisis particularly the case, given that the MC has no obligation to keep metering data but ratherrelies on the MDP for this recording.

Further it should be made clear here that the MC does not need to archive all metering dataitself, but rather only all records after the dispute in declared under Cl 8.2.

3RESPONSIBILITY FOR METERPROVISION



3.1 Overall requirements

3.1. Overall requirementsMCs 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 andthe metrology procedure, as appropriate.

MCs are responsible for the design of a metering installation and warrant that the designcomplies with the components, characteristics and service requirements specified in the NERand this Procedure.

MCs must ensure the components have been selected, properly installed and initially tested bythe MPs so that the metering installation satisfies the relevant accuracy and performancerequirements in the NER and the metrology procedure.

These three sub clauses (We cannot give reference numbers as these have not beenincorporated in this revised version !!) by virtue of their different wording with respect to the MCactions 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 threedifferent wordings that there is rather one approach: the MC has the role and responsibility toensure compliance hence the term used must be "ensure". The clause re "use of MPs" issuperfluous as this is already their obligation under the Rules 7.3.2.

3.1 Overall requirements

MCs must ensure the components have been selected, properly installed and initially tested bythe MPs so that the metering installation satisfies the relevant accuracy and performancerequirements in the NER and the metrology procedure.

Although the split between the MEP and the SLP is not clearly defined in the Frameworkdocument it would appear that the SLP would have a role and should be added to this clause.



4METERING INSTALLATIONCOMPONENTS

4. METERING INSTALLATION COMPONENTS

The components, their characteristics, and associated service requirements for meteringinstallations 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 Section7.8.2, the components as detailed in this Section 4.

4.1Requirement under NationalMeasurement Act and use ofStandards

Current proposed words:

New CTs for type 1, 2, 3, 4, 5 and 6 metering installations must meet the relevant requirementsof AS 60044.1 and must also comply with any applicable specifications or guidelines specified bythe 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 requirementsof AS 60044.2, AS 60044.3, AS 60044.5 and AS 1243 and must also comply with any applicablespecifications or guidelines (including transitional arrangements) specified by the NationalMeasurement Institute under the National Measurement Act.

Use of the term "new" in these clauses implies that different standards can be applied tocomponents which are not "new". That is that there could be components in service or in stockwhich were legitimately purchased to standards specified at the time but which do not meetthese requirements for new components.

However Section 4.6 of this redrafted MEP includes grandfathering which applies to componentsfrom before 2008 but there is nothing re the grandfathering of components which have beenpurchased after 2008 but which do not meet the current requirements in these clauses.

The situation re these should be made clear.




The MC must ensure that a visible display is provided to display, at a minimum, the cumulativetotal 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 allrequirements. Hence for example they must ensure the requirements in the three clauses aboveapply but this is NOT stated in these clauses.

Hence remove reference to MC must ensure in this clause.


Any programmable settings available within the metering installation, or any peripheral devicethat might affect the resolution of displayed or stored data must meet the relevant requirementsof AS 62052.11, AS 62053.21 and AS 62053.22 and must comply with any applicablespecifications or guidelines specified by the National Measurement Institute under the NationalMeasurement Act.

Not sure whether this clause is required. The Aust Standards quoted are the same as those inthe 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 meteringinstallation. Delete this phrase.

Move clause under the first clause of this Section 4.1 which also deals with meters.

* Note also "might affect" is unnecessarily vague - it either affects the data or it doesn't.Delete "might".

4.2Use of optical ports andpulse outputs

The MC must provide pulse output facilities representing the quantity of electricity measured inaccordance with the relevant Australian Standard for that meter within a reasonable time ofbeing 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 .......




A type 4A or 5 metering installation must have an optical port that meets the AS 1284.10.2 or AS62056.21 or a computer serial port to facilitate downloading of 90 days of interval energy data foreach 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 thesubheading for "Pulse Outputs".


Where the metering installation includes equipment for load control or the measurement ofreactive energy, the installation and operation of that equipment will be governed by aninstrument other than the metrology procedure, for example, a ‘use of system’ agreementbetween 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 specialmention outside the metrology requirement to provide these readings as required.

4.3 Password allocation

4.3. Password AllocationThe MP must allocate “read-only” passwords to FRMPs, LNSPs and AEMO, except whereseparate “read-only” and “write” passwords are not available, in which case the MP must allocatea password to AEMO and the MDP only.

It is unclear to AusNet Services why this refers specifically to an MP obligation rather than usethe more usual and more correct "the MC must ensure...."

4.4“x” values – calculation anduse

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 isallocated 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 theAverage Daily Load as the basis of the comparison with the volume threshold for "x"."



4.5“y” values – calculation anduse

4.6 Grandfathering

The proposed wording is:

Meters and components for a type 5 or 6 metering installation, which were installed, or whichwere 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 asthis was the party involved at the time.

4.6 Grandfathering

The proposed wording is:

Metering installations which that have been installed, or which are held in stock for the MC in aJurisdiction, prior to the effective date of that jurisdiction’s initial metrology procedure and ........

This should read:

Metering installations which that have been installed, or which were held in stock for theresponsible person in a specific Jurisdiction, prior to the effective date of that Jurisdiction’s [leadcap] initial metrology procedure and ........

4.7Data storage requirementsfor meters

4.7. Data Storage Requirements for MetersA type 4A or 5 metering installation must have the capability of storing interval energy data for a periodof 200 days. Components of a type 5 metering installation installed or held in store for the responsibleperson prior to 1 January 2007 must have the capability of storing interval energy data for a period of atleast 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 inservice) should continue to be grandfathered.

4.8 Meters and clocks



4.9 Interval Meters

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 dataThe data that results from the measurement of the flow of electricity in a power conductor wherethe data is prepared and recorded by the metering installation in intervals which correspond to atrading interval or are submultiples of a trading interval.

The definition in the metrology procedure therefore needs only to define the basis ofsubmultiples of a trading interval

Suggest wording should be:

Where a metering installation records interval energy data and the interval periods are based onparts 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 thehalf- hour and on each quarter of an hour (EST).

· Other sub-multiple intervals, where agreed with AEMO, the LNSP and the relevantMarket Participant, provided that the ends of the intervals correspond each and everyexact hour (EST) and half- hour (EST).



5MINIMUM SERVICESSPECIFICATION

The services set out in the minimum services specification apply to the capability of the meteringinstallation itself.

A metering installation is defined as:

metering installationThe assembly of components including the instrument transformer, if any, measurementelement(s) and processes, if any, recording and display equipment, communications interface, ifany, 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 forcollection.

Hence the concept of this additional clause appears flawed and superfluous as the definitionlimits the extent of the obligation to the components of the MI ie at the site only.

5.1 Minimum Service Levels

AusNet Services consider that limiting the applicability of these Minimum Service Levels to theMetering Installation is not consistent with either the intent or the wording of Cl 7.8.3 of theRules. We consider that it is clear that the desired outcome is to define the minimum capabilitythat the end to end facilities that an MC, in offering to provide a Minimum Service Specificationservice, must have in place.

Whilst the wording of this Rules clause 7.8.3 could have been clearer , the interpretation thatthe Minimum Service Levels only apply to the MI leaves a significant gap in the regulatoryframework for smart meter services and fails to support a fundamental outcome of the MeteringContestability regime of facilitating access to quality advance meter services by Distributors andthird parties. To interpret Cl 7.8.3 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 toend service levels. These could then be specified in another Procedure or added to the MEP in asecond release.

However despite the above being the AusNet Services view we have also made comment on theproposed MI service levels drafting proposed by AEMO.




5.1. Minimum Service LevelsThe minimum service levels are made up of two elements: service availability and completiontimeframes.

To be consistent with the broad intent and drafting approach of the MEP this section should berewritten as clear requirements/obligations:

Rewrite as below or similar:

A small customer metering installation must meet the minimum service specification inaccordance with the two elements of the Minimum Service Levels [this should be in the Glossaryas a defined term]: service availability and completion timeframe.


5.1.1. Service AvailabilityExcept for periods of a lack of supply, metering installations must be capable of meeting theminimum services specification at all times.

"lack of supply" is not a very precise term. This clause should cover more than a distributionnetwork 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....."




5.1.2. Completion TimeframesThe completion timeframes for each service are detailed in Table 5.1. They will be measuredfrom the time a request is received by the metering installation to the time of completion of therelevant service by the metering installation.

This should be rewritten: as a clear requirement/obligation with clarity of the service outcome measure

Suggested revised wording:

A small customer metering installation must meet completion timeframe [singular] for each MSSservice 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 todeliver the service at a point in time or to a requested schedule. Hence the completiontimeframe must be measured to the availability of the notification of completion. Proposedwording is taken from the definition of Metering Installation in Chapter 10. [Note this Rulesdefinition should be revised for the Metrology Procedure as the metering installation is nowproviding more than "metrology" outcomes]



5.2 Completion Rates

5.2. Completion RatesThe completion rates for each service are detailed in Table 15.1. The MC must be able to provideevidence demonstrating that small customer metering installations are capable of performing to thecompletion 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 detailedin Table 15.1.

The wording:

The MC must be able to provide evidence demonstrating that small customer meteringinstallations 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 therequirements of the metrology procedure and hence to single out this requirement issuperfluous, and could be taken to indicate that other capabilities do not need to bedemonstrated on request.




5.3. Technical RequirementsThere 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, themetering installation must be capable of recording and providing the average voltageand current over a nominated trading interval for one or more nominated tradingintervals, for each connected phase.

To be consistent with the broad intent and drafting approach of the metrology procedure thissection should be rewritten as clear requirements/obligations:


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




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 considerthat these are capabilities of the meter which must be specified in a purchased meter to enableit to reasonably support the envisaged outputs required for smart meter services.

We are unclear what Technical Requirements would require to be specified in the metrologyprocedure compared to those to be specified in a revised Australian Standard for meters. Whatis the basis of the distinction as understood by AEMO?

However at least in the shorter term the metrology procedure is the ONLY place where theseTechnical Requirements can be specified, as we understand that the Australian Standard will notbe in place and enforceable as the basis of meter designs and purchases until well after the startof Metering Contestability.

AusNet Services consider that the Technical Requirements on this basis must include:

auto-disconnection for a remote re-energisation of an installation with current flowingabove settable limits and time periods as specified in the Victorian AMI Specification orsimilar. This is an essential safety feature and must be within the meters capabilities ie it isa Technical Requirement.

meter internal temperature alarms which Victorian experience has shown to be essential tothe prevention of meter fires with potential Health and Safety implications

capability for routine delivery of power quality data (volts, amps etc as specified in theMinimum Service Specification meter enquiry service. The routine delivery of power qualitydata was a clear requirement identified in the AEMO advice to COAG re the services fromsmart meters. It is the AusNet Services’ view that this must be a capability built into themeter. The capability of the meter to measure the power quality data parameters and tostore a single snapshot “set” is not sufficient capability to delivery routinely a set of powerquality data frequently measured and stored throughout a day.

there may be others which need to be included?




Table 5.1 Minimum Service Levels and Minimum StandardsCompletion Timeframe

AusNet Services are disappointed that AEMO has provided no assessment nor analytical basisfor the Completion Timeframes in this Table.

Whilst AusNet Services do not have firm suggestions for this measure, we are concerned thatthe "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 governsthe usefulness of the service to the industry. The industry have raised the need for "near realtime access" to some services and on this basis have suggested that the transaction handlingtimes 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 andconsider that further analysis and "justification" is necessary before this could endorse this as ane-Hub requirement, it would appear to be inconsistent to have one part of the end-to-endservice path being specified as less than 20 seconds but allow within the metrology procedurefor 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 propertechnical analysis of meter capabilities.




Table 5.1 Minimum Service Levels and Minimum StandardsCompletion Rate

AusNet Services are disappointed that AEMO has provided no assessment nor analytical basisfor the Completion Rates in this Table, nor a clear definition of the measure.

The stated requirement is that the meter responds in the Completion Timeframe for 99.5% ofservice requests. And hence conversely does not respond in the specified CompletionTimeframe in 0.5% of requests. That is for 1 in 200 requests the Timeframe is longer. Or overa 12 month period of somewhat regular service requests, almost two days of service requestsare not processed in the meter in the desired timeframe.

This would appear to be rather poor performance from what is essentially a relatively simpleelectronic device presumably specifically designed for reliability and high availability.

Does AEMO have analysis which supports this as the best possible outcome that can reasonablybe delivered by advanced meters??

AusNet Services consider that this completion rate measure should be subject to a propertechnical analysis of meter capabilities with the aim of validating that this can be significantlyimproved.




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, theoutcome action for each of the services must be clear.

This is particularly evident with respect to setting up a scheduled read service.

The requester is wanting the MC/MP/MDP to establish a meter reading schedule to enable thedelivery of metering data to the requester’s requirements. The required outcome at the meter isto 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 timedelay for establishing the read schedule is not particularly critical.

Each of the completion timeframes should be considered against the business requirements forthat service. A blanket 1 minute is too long for some time critical services and potentially toshort for services where timing is not critical.

6 SUMMATION METERING

7 EMBEDDED NETWORKS

8REVERSION OF METERINGINSTALLATION TYPES



9ROUTINE TESTING ANDINSPECTION OF METERINGINSTALLATIONS

9. ROUTINE TESTING AND INSPECTION OF METERING INSTALLATIONS

Unless the MC has an Asset Management Strategy, metering installations must be tested andinspected in accordance with clauses 7.9 and S7.6 of the NER. Section 9 specifies AEMO’srequirements in respect of a proposed asset management strategy that an MC will need to takeinto 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 andinspected 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 ofan Asset Management Strategy ..

9ROUTINE TESTING ANDINSPECTION OF METERINGINSTALLATIONS

This clause currently states:For those meters for which new or amended pattern approval has been received from theNational Measurement Institute or, in the absence of pattern approval, new or amended typetesting has been undertaken by a NATA accredited laboratory or a body recognised by NATAunder the ILAC mutual recognition scheme, the MC must ensure that the Sample Test Planstipulates that this population of meter is tested at least once in the first three years of beingplaced in service.

AusNet Services view is the Sample Test Plan requirement should not just apply to meters “forwhich new or amended pattern approval has been received from the National MeasurementInstitute or, in the absence of pattern approval, new or amended type testing has beenundertaken by a NATA accredited laboratory or a body recognised by NATA under the ILACmutual recognition scheme” as specified in the first part of this clause but rather apply to ALLmeters.

Further the Australian Standard re Sample Testing of Meters requires the first sample test to becarried in the second or third years of service (not in the first year) and the wording should reflectthis requirement.



10 INSTALLATION OF METER(S)

The MC must use reasonable endeavours to ensure that, at the time of installation, a meteringinstallation is:(a) protected against damage;

(b) installed in such a way that it allows safe and unimpeded access to the End User or anyperson whose obligation it is to test, adjust, maintain, repair, or replace the metering installation,or to collect metering data from the metering installation; and

(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 viasafe, convenient and unhindered access when it is not located at the Site.

The list of metering installation requirements should be expanded by adding the following:

(d) installed in compliance with the Distributor's reasonable technical requirements.

ie in Victorian the SIRs


(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 viasafe, 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 theclause as it was previously drafted.

It was meant to ensure that where the MI was installed not within the area of a site which wasgenerally accessible by the End User ie not located at their premises, but located at the Site (ieat the address of the land on which their premises is located), that the End User must be givenaccess to their metering installation. eg in a block of factories, the meters for all factories may beinstalled in a common service area and this area must be accessible for all factoryowners/lessees.

The term "End User's premises" better describes the requirement.




In accordance with clauses 7.8.6 of the NER, the MC must not unreasonably withhold its consentto a request from a Market Participant or LNSP to install a metering installation of a type that isdifferent from that already installed, or provide facilities in addition to that which the MCotherwise would install, provided that the metering installation satisfies any applicable technicalrequirements (including those reasonably required by the LNSP) and complies with the NER andthe metrology procedure applicable to the metering installation type.

It is not clear to AusNet Services that the NER now provides any clear support for an MC makinga change to a MI at the request of a Retailer (except presumably under any contract the retailerhas with the MC) or at the request of a Distributor. There would appear to be no equivalentclause to 7.3.1(c) in the current Metering Contestability version of NER Chapter 7.

Therefore this clause should be removed from the metrology procedure?




Where a Market Participant or LNSP requests in writing for the MC to provide and install ametering installation, the MC must use reasonable endeavours to provide and install themetering installation within 20 business days of receipt of the written request. Note, an exceptionto this requirement is where high voltage equipment procurement with long lead times isrequired.

AusNet Services comments:

i) Does the LNSP still have the right to request the MC install a MI? Which NER clausesupports that right?

ii) Most appointments ie contracts for installation of meters is done on the basis of notificationthrough MSATS CRs. There is no specific "request in writing" and hence this clause shouldbe revised on that basis.

ii) “reasonable endeavours” is written in italics - where is it defined in the NER?

iv) The Distributors currently have defined timeframes for the connection of customers. Whensupply is available at the customer boundary these timeframes are relatively short (inVictoria 10 bus days). Currently for most small customers this connection timeframeincludes the installation of the meter, testing and energisation.

It would appear to be inconsistent therefore for the metrology procedure to assign atimeframe of 20 days for the MC to respond to the Retailer request and install thecustomer's meter. Further any meter installation time frames assigned needs to beconditional on the customers Electrical Contractor providing the necessary facilities andaccess etc on site.

AusNet Services consider that this aspect of the meter installation process has beeninadequately considered in the drafting of this clause, and it should be redrafted to betterreflect the coordinated approach between the physical connection and the meterinstallation and the relative timing in the Metering Contestability regime.




New Connections and changes to installation (eg 1ph to 3 ph) will in AusNet Services’ viewrequiring testing by a DNSP. In Victoria this is a requirement of the Victorian Electrical SupplyIndustry “VESI Installation Supply & Connection Test Procedures (ISCTP)”.

In the current metering framework the majority of meters (except in NSW) are installed byDNSPs as part of establishing supply. The meter and electrical installation are tested intoservice by the DNSP prior to the seals being applied to the meter terminal box.

In the Metering Contestability regime the usual practice will be for the meter to be installed priorto the DNSP carrying out the necessary testing. Hence the meter terminal box will be sealed bythe MPB prior to the DNSP doing the testing. However the DNSP, to carry out the necessarytesting, may need to gain access to the meter terminals. To do this the DNSP will need to breakthe MPB applied seals and reapply seals after the testing.

The NER states:

7.15.2 Security of metering installations(a) The Metering Coordinator at a connection point must ensure that the metering installation is secureand that associated links, circuits and information storage and processing systems are protected by securitymechanisms acceptable to AEMO.(c) If a Local Network Service Provider, financially responsible Market Participant, Metering Provider orMetering Data Provider becomes aware that a seal protecting metering equipment has been broken, itmust notify the Metering Coordinator within 5 business days.

It would appear to be unnecessary for the DNSP to notify the MC in the circumstances ofinstallation testing as detailed above. AusNet Services considers that the Metrology Procedureshould provide an “interpretation” of the NER clause 7.15.2, such that the DNSP does not needto carry out this unnecessary notification.




If the pricing arrangements for the supply of electricity in respect of a connection point changeand the metering installation is thereafter incapable of appropriately measuring and recording theamount of electricity supplied to that connection point, the MC must provide, install, commission,test and maintain the metering installation to appropriately measure and record the amount ofelectricity supplied to the connection point.

The relationship between pricing (ie tariffs) and meter installation capability to support theRetailer and/or Distributor tariffs is far from clear in the Contestable Metering regime.

Whilst NER clauses make it clear that the MI must have the capability to measure the energyconsumption at a NMI, there would appear to be no specific obligation on the MC to ensure thatthe MI supports the Retailer and/or Distributor tariffs. Whist the retailer or the customercontracting the MC would presumably contract for a MI to support their desired tariff, it would notappear to be reasonable for the commercially sourced MC to be obliged in this metrologyprocedure to change the metering installation to align with a tariff change unless is a requirementof their commercially contracted service.

This clause therefore should be removed.

10.1 Installation by ASPs

11 METER CHURN

It is not clear on what basis the content of this Section was inserted into the Metrology Procedurerather than:i) relying on the requirements and obligations in the NER, and/orii) covering the detail in the Churn coverage in the MPB SLP.

Knowing the basis would have made commenting more certain.

AusNet Services have made comments on the content in the Metrology Procedure, but weconsider that most/all of this could be better covered with the other meter churn coverage in theMPB SLP.



11.1Who can Initiate a MeterChurn

11.1. Who can Initiate a Meter ChurnThe MC for a metering installation can initiate a Meter Churn at any time.

It is the AusNet Services understanding that change of the meter at an installation can beinitiated by parties other than the MC including:

unless restricted by their commercial contract with the MC, an MP can initiate a meterchurn

a retailer can initiate a meter churn potentially through their contractual relationshipwith the current MC or through a change of MC.

a large customer can initiate a meter churn potentially through their contractualrelationship with the current MC or through a change of MC.

Further, to be consistent with the broad intent and drafting approach of the MetrologyProcedure, this section should be rewritten as clear requirements/obligations.

Hence this Metrology Procedure requirement should rather be:

A MP must only carry out a Meter Churn at the request of a Retailer nominated as the FRMP inMSATS or the MC nominated in MSATS.

11.2Who can Perform the MeterChurn

11.2. Who can Perform the Meter ChurnOnly MPs with the appropriate accreditation can perform a Meter Churn.

To be consistent with the broad intent and drafting approach of the Metrology Procedure thissection should be rewritten as clear requirements/obligations:


An MP must not carry out a Meter Churn unless it has accreditation for meters of the MeteringInstallation Type Code of the meter being installed.



11.3How is a Meter Churn to bePerformed

When a Meter Churn is initiated, the MC must ensure:(a) information is made available to any New MP to facilitate the Meter Churn, which includes:

(i) the NMI;

(ii) the Site;

(iii) the meter serial number(s) of the meter(s) to be removed;

(iv) the name of the Current MP and its Participant ID;

(v) the name of the Current MDP and its Participant ID;

(vi) the current metering installation type; and

(vii) instructions on the required changes;

The requirement for at least some of this data will apply not only to a New MP but also to the"Current MPB" who has been requested to carry out a Meter Churn.

It would be our view that an MC will in general NOT have this all this data for a site to whichthey have been newly appointed by the FRMP/customer.

It will generally fall to the MPB to obtain this data and would potentially do this through a B2Brequest to be established by the IEC.

The Metrology Procedure should be written on the basis of practical outcomes not on the"theoretical" model of the MCs having an all embracing centralised role. The NMI, the addressof the Site, and the new metering requirements are the only detail generally available to a newMC.

11.3How is a Meter Churn to bePerformed

When a Meter Churn is initiated, the MC must ensure:(b) all Role assignments in MSATS for the connection point comply with the MSATS Procedureswithin 2 business days of the Meter Churn; and

This obligation on the MC is not specifically reflected in the CATS Obligations by Role.



12

DE-COMMISSIONING ANDREMOVAL OF METERINGEQUIPMENT AND NETWORKDEVICES

Before de-commissioning all or any part of an existing metering installation, the MP undertakingthe work must ensure that:(a) Arrangements are put in place to ensure a Final Reading is taken, at the time of de-commissioning, of all metering data maintained in the existing meter; and

(b) The ownership of the existing meter is ascertained and arrangements made for the meter tobe returned to its owner within 10 business days unless otherwise agreed with the LNSP.

Why is this restricted to the LNSP?? This clause must apply to the LNSP as the initial/deemedMC and any subsequent MCs.

12

DE-COMMISSIONING ANDREMOVAL OF METERINGEQUIPMENT AND NETWORKDEVICES

Before de-commissioning all or any part of an existing metering installation, the MP undertakingthe work must ensure that:(a) Arrangements are put in place to ensure a Final Reading is taken, at the time of de-commissioning, of all metering data maintained in the existing meter;

Where the metering data from the Final Reading is not transferred to the relevant MDP at thetime of de-commissioning, the owner must ensure the metering data or Final Reading (asapplicable), is provided to that MDP within two business days of receipt of the meter.

The obligation in (a) is clearly on the MP to ensure a Final Reading [definition is not included inthe Glossary] is taken. This requirement is correctly allocated to the MP as they are the partymaking the meter change. The obligation on the owner to provide metering data for the finalread should only extend to Type 5 meters, and only where the MP has returned the meter to theowner.

Having correctly assigned the obligation to the MP for meter Types other than Type 5, theMetrology Procedure should not also allocated the obligation to the owner presumably if the MPfails in their obligation. This clause should be made more specific to limit this obligation to onlyType 5 meters.

12.1 Network Devices

The following clause is proposed:

12.1.1. Deemed Network DevicesFor the purposes of clause 7.8.6 of the NER, an existing metering installation that is to bereplaced by an MC will be treated as a network device only if the metering installation is doingsomething other than supporting the application of a network tariff.



AusNet Services does not support:

the Metrology Procedure providing a definition of what constitutes a Network Devicewhich does not align with the definition in the NER, and

the Metrology Procedure assigning the interpretation of the Metrology Proceduredefinition to the MC/MPB.

The reference to the component "doing something other than supporting the application of anetwork tariff" is not a useful one. For example a LNSP meter may be only providing meteringdata to the LNSP and not other services. However it may be doing so when required by anetwork application used to monitor or control the network. How would the MC differentiate asto whether this was the case and that the metering data was not just providing tariff support?

The NER defines a network device as:Apparatus or equipment that:

(a) enables a Local Network Service Provider to monitor, operate or control the network for thepurposes of providing network services, which may include switching devices, measurementequipment and control equipment; and ...

Consistent with this definition AusNet Services considers that the following wording or similarshould be used:

For the purposes of clause 7.8.6 of the NER, any components of an existing metering installationprovided and installed by the LNSP that are potentially to be replaced by an MC must be treatedas a network device unless the LNSP has provided:

notification that the existing LNSP metering installation at the specific site is notrequired to be retained as a network device, or

general details of the LNSP metering installations which are not required to be retainedas a network device, or

details of the terms and conditions under which the LNSP would commercially sourcethe required services from the MC/MP meter and hence not require the LNSP meteringinstallation to be retained as a network device

The next clause provides the controls over what specific MC actions can be carried out.




12.1.2. Removal during Meter ChurnA network device can only be removed during a Meter Churn:(a) where the relevant MC and the LNSP agree to its removal; or

(b) where the network device provides a:

(i) control service that facilitates the application of a Network Tariff at the NMI, such as thecontrol of a hot water, and that service is obsolete as a result of the Meter Churn; or

(ii) switching service that facilitates the application of a Network Tariff at the NMI, such as atimeclock or time switch used to change the register on a multi-register meter, and that service isobsolete as a result of the Meter Churn.

This wording should be revised as:

A MC or appointed MPB cannot remove a network device , or take any action that adverselyimpact on its operation during a Meter Churn or at any other time except where:

(a) the relevant MC and the LNSP agree to its removal; or

(b) where the network device is impacting the MPB installing a market meter

AusNet Services consider that the Metrology Procedure should not detail the provisions:

(c) where the network device provides a:(i) control service that facilitates the application of a Network Tariff at the NMI, such as the

control of a hot water, and that service is obsolete as a result of the Meter Churn; or(ii) switching service that facilitates the application of a Network Tariff at the NMI, such as a

timeclock or time switch used to change the register on a multi-register meter, and that serviceis obsolete as a result of the Meter Churn.

If the LNSP has no concerns in specific circumstances for network provided devices to be notconsidered as network devices, the LNSP will define these circumstances as per theAusNet Services proposed wording for Clause 12.1.1.

12.1 Network Devices AusNet Services consider that the removal of a network device by a MC/MP




12.1.3. LNSP Obligations if Alterations to Metering Installations RequiredWhere an LNSP considers that an alteration is required to a metering installation toaccommodate, remove, or replace a network device installed at or near the metering installation,including the removal of any seal, the LNSP must:

(a) agree the alterations with the affected MC and MP prior to the commencement of anyalterations;

The newly drafted MP SLP states in section 4.4 re meter churn:

b) where the metering installation does not include instrument transformers, the MP must:

i. make reasonable endeavours to contact the Current MP to confirm that Meter Churn is to becarried out; and …..

AusNet Services considers that the requirement on the LNSP with respect to alterations to theMI with respect to network device should be no more stringent. The requirement to haveagreement from the MC and the MP before the work is carried out appears overly arduouscompared with the requirement for a replacement of the official market meter.

Further the notification should be to the MC OR the MP. A requirement to notify both is overlyarduous and generally inconsistent with other clauses in the Metrology Procedure which requirenotification of meter work.

(b) ensure any work performed on the metering installation is undertaken by a suitablyaccredited MP; and

Current metering work in Victoria can be carried out by suitably qualified LNSP personnel.AusNet Services consider that this arrangement will continue to apply for Victorian DNSPs’network devices. Hence (b) should be reworded:

(b) ensure any work performed on the metering installation is undertaken by a suitablyaccredited MP or by otherwise suitably qualified LNSP personnel as defined in Jurisdictionalinstruments; and



(c) ensure that the MC and MP are provided with details of the alteration, including any newseals.

AusNet Services consider that there will be industry standard approaches to the connection ofnetwork devices (in Victoria defined in the SIRs) and hence it is not therefore appropriate toexpect the LNSP to provide details of the installation to the MC and MP. LNSP personnel aresuitably qualified to carry out work on meter panels including the necessary sealing of meteringequipment. Notification of replacement seal details is unnecessary.

12.2Request for testing type 1 –6 metering installations

13RESPONSIBILITY FORMETERING DATA SERVICES

13.1 Metering data services

The MC , or FRMP (where applicable) must use MDP(s) for the provision of metering data services inaccordance with clause 7.3.2 of the NER.

The MC is responsible for the appointment of the MDP (although the FRMP may indicate theirpreference of MDP choice) and hence the alternative of the FRMP choice should be removed:

The MC , or FRMP (where applicable) must use MDP(s) for the provision of metering data services inaccordance with clause 7.3.2 of the NER.

13.2 Metering data collection

13.3 Metering data storage

13.4Access to energy data andmetering data

13.5Verification of metering datafor type 4A, 5, 6 and 7metering installations



13.6Metering installation type 7– sample testing

13.7Request for test ofcalculated metering data

13.8AEMO’s Metering DataObligations

14EMERGENCY PRIORITYPROCEDURES

Clause 7.8.5(b) of the NER requires AEMO to establish emergency priority procedures.

Remove - superfluous wording repeating NER statement of requirements.



14EMERGENCY PRIORITYPROCEDURES

It is AusNet Services view that the AEMC drafting expected that there would be some morefundamental basis for emergency actions by the MC on behalf of the LNSP as a result of anemergency.

The AEMO drafting appears to expect that commercially based service agreements will be struckby LNSPs with all MCs for all connection points with smart meter capabilities. It is theAusNet Services view that this was not what was expected as the basis of emergencymanagement utilising smart meter capabilities. It is the AusNet Services view that the conceptwas that in an emergency, irrespective of the specific commercial agreements in place betweenthe LNSP and MCs, that the MC would accept and act on LNSP service requests and do soahead of any other MC actions.

To require specific commercial contracts for actions to protect the integrity of the network andpotentially impacting on public safety and life threatening situations appears to be a significantbarrier to the use of smart meter services in these scenarios.

The AEMC’s position is not clear in the NER Section 7.8.5 but the following clause 7.3.2 (i) (2)(iv) clarifies that the AEMC expects action from the MC when the emergency priorityprocedures are in affect.

(i) The Metering Coordinator at a connection point with a small customer meteringinstallation must:(2) not arrange a disconnection except:

(i) on the request of the financially responsible Market Participant or Local NetworkService Provider;(ii) where such disconnection is effected via remote access;(iii) in accordance with jurisdictional electricity legislation; and(iv) if applicable, in accordance with the emergency priority procedures;

AusNet Services consider that the specifics of how smart meter services may provide essentialactions in an emergency needs further industry debate and the need for mandated action by allMCs irrespective of their commercial contracts with LNSP should be part of that debate.



14.1Criteria for determiningEmergency Condition

While AEMO does not intend to restrict LNSPs and MCs from agreeing on a definition of‘emergency condition’ in their service agreements, AEMO expects the definition to take intoconsideration the following criteria:…..

It is very unclear what obligation this is trying to impose on LNSPs and MCs? Does this suggestthat the LNSP and the MC must have a service agreement re emergencies? This would appeara reasonable approach to prevent an MC refusing to establish a service agreement. Does thewording suggest that the agreement must cover the listed aspects of an emergency?

AusNet Services expects that the wording should hence be as below or similar:

Each MC must establish when requested by an LNSP, a service agreement for the action of theMC under an emergency as defined in the emergency priority procedures. The serviceagreement must cover at least the following defined emergencies:

Disruption to power supply to one or more Sites, regardless of duration

Risk of environmental damage, injury or fatality to any person from distribution networkequipment due to their proximity to that equipment

Potential for or the presence of risk to public safety.

Mandatory restriction of power supply

Disruption to communications network used in the delivery of metering data

14.2Metering InstallationsAffected



14.3Prioritisation of Services byMetering Coordinator inEmergency Condition

LNSPs may prioritise the delivery of services from MCs in their services, by agreement or adhoc, provided that those services that are required for safety purposes, such as disconnection orreconnection are prioritised over those services that are required purely for commercial reasons.

It is very unclear what is the intent of this wording. For example:

What is the concept of “by agreement or ad hoc”?

What is the concept of “those services that are required purely for commercial reasons”?Many (most?) services requested by LNSPs will not be for “commercial reasons” butrather to fulfil a regulated obligation of the distributor. The differentiation is betweenservices for handling an emergency and those same services being utilised in a non-emergency ie routine situation.

14.4 Other Laws Prevail



4. Metrology Procedure: Part B



1 INTRODUCTION

1.1. Purpose and Scope

1.2.Definitions andInterpretation

1.3. Related DocumentsThese documents should also include references: MDPSLP, MDFF Procedures, MDM Procedures

2

PRINCIPLES FORVALIDATION,SUBSTITUTION ANDESTIMATION

2.1. General Validation,Substitution and

In relation to the following deleted paragraphs, AusNetServices recommends moving these deleted provisions inthe Metrology Procedure Part B to section 10.1, “the



Estimation Requirements MDP must authenticate all Validation failures to ensuremetering data accurately reflects the energy flow” and“the MDP must Validate all Substitutions and forwardEstimations before metering data is delivered to AEMOand Registered Participants”. These authenticatingValidation failures and Validating subs and estimates arecritical aspects of MDP operations. Although further inthe Metrology Procedures Part B there are obligations toValidate all interval metering data, it appears thatremoving these paragraphs leaves critical aspects of MDPoperations unaddressed.

In relation to "the MC must respond promptly to requestsfor remedial action from the MDP or AEMO", AusNetServices consider that the MC cannot take "remedialaction" other than to provide the coordination andcontract management of the various parties as requiredby the first part of this clause. Also the MC engages theMDP through a commercial agreement. Suggest wordingbetter reflect this as mandated MC action: The MC mustrespond promptly to requests for this coordination fromthe AEMO.

The timeliness of MDP(s) detection of metering dataerrors and MC(s) response place more than just theretailers at financial risk, rather it places the DNSP atfinancial risk. AusNet Services suggests altering theparagraph to refer to “retailers and the DNSP” and referto “affected Registered Participants” instead of “affectedMarket Participants”.

Regarding the last paragraph in 2.1, there is no concept in



the detail of this MEP Part B of "any default Substitutionprocedures agreed to with the MC". The onlysubstitution type where the MDP (and the MC) hasdiscretion is type 55. Here the decision, as currentlyworded, is not with the MDP/MC but rather with theimpacted Participants. Currently the MDP and MCcannot agree a default Substitution procedures approachand publish this approach to Registered Participants.However, AusNet Services as per our comments on thetype 55 approach, is supportive of the concept of a "MDPdefault approach for type 55". If this were adopted thenwording similar to the current wording of this clausewould be consistent.

2.2. Substitution requirement

Regarding the first paragraph in 2.2, The phrase "onbehalf of AEMO or the MC, as appropriate," is inconsistentwith the redrafting approach as the requirements ofAEMO or the MC to ensure subs and estimates is definedin the NER and the Metrology Procedure Part A.

The concept of "not completed Validation", in 2.2(f), isnot consistent with the obligation to Validate all intervalmetering data. These words should be removed.

The current proposed words in 2.2(h)(i) make referenceto more than one SLP (MDP), but there is only one SLP(MDP). Hence, it should read “metering data formetering installations with remote acquisition must beSubstituted if metering data cannot be obtained to meetthe required performance of the SLP (MDP).”

Regarding 2.2(j), it is AusNet Services view andunderstanding that it is the MDP role under their



accreditation and the MC's responsibility under this MEPto ensure that metering data meets the metrologyrequirements. Hence whilst the FRMP, LR, and LNSP canagree on what they consider the sub should be, theycannot and should not, "direct" the MDP as ultimately itis the MDP's role to ensure data consistent with themetrology requirements.

2.2(k) refers to “type 7 metering data” but elsewhere insection 5 the term is replaced with “calculated meteringdata”.

Regarding 2.2 (n) AusNet Services is unclear why thereference to "transfers authorised by a participatingjurisdiction". Is this to recognise that in Victoria ROLR isnot under the AER? If so, the clause could read "(n) Inresponse to End User transfers as required by the ROLRProcedure."

2.3. Estimation requirement

Regarding 2.3 (a) AusNet Services consider the realrequirement is for estimated metering data to beavailable to meet the settlement timeframe. Hencethere is no requirement for metering data to be availableup to the next Scheduled Reading Date, although thismay be a convenient approach for MDPs and currentbenchmark approach. Reword to “Routinely for a periodthat is equal to or greater than the period to the nextdata delivery required as per the AEMO SettlementTimetable.”

Regarding 2.3 the Victorian policy variation, the referenceto the “data requirements of Schedule 8 of the data



requirements of Schedule 8 of the Service LevelRequirements for Metering Data Collection, Processingand Delivery Services for Metering Provider category 5D,6D and 7D” is no longer correct since the MDP SLPs havebeen amalgamated.

2.4.Metering data qualityflags

Regarding the current proposed wording “A - forValidated and accepted accumulated metering data orinterval metering data recovered from the meteringinstallation”, the generally accepted terminology is thatValidated metering data is data that has passedValidation. The "and accepted" is not required under thisusage of the term. If the "and accepted" is considered tobe required then it should be applied consistently in theMetrology Procedures and the SLPs. Further, the words"recovered from the metering installation" aresuperfluous as metering data by definition is from ametering installation. Hence becomes “A - for Validatedaccumulated metering data or interval metering data

Regarding the current proposed word “F - forSubstitutions that are of a permanent or final nature andsubject to section 3.7.3, the metering data would not bereplaced by accumulated metering data or intervalmetering data at any time”, given that by virtue of therequirements in clauses in other parts of Section 2.4these are not necessarily permanent the clause isincorrect. The following wording is more correct, andconsistent with the other Quality Flag descriptions. “F -For Substitutions that are considered to be likely of apermanent nature and subject to requirements in thissection below, the metering data would not likely be



replaced by other accumulated metering data or intervalmetering data at any time.”

Current proposed wording must updated to reflect thenew numbering. F metering data can only be replacedwith F metering data as per clause section 3.4.3(f) 2.4(f)or A metering data as per clause section 3.4.3(b) 2.4(b) or3.4.3(h) 2.4(h).

Regarding the words in 2.4(b) “… and maintain a recordof the reason and instance” what is the intent of “andinstance”? The instance is actually reflected in themetering data itself hence these words are superfluous.AusNet Services recommends removing the words “andinstance”.

Regarding 2.4(h), AusNet Services considers that thereplacement of any subs whether Final or temporary innature by Actuals is mandated in the final clause inSection 3.2 and agreement of the FRMP, the LR and theLNSP is not required. Further, where the MDP considersthat a previous final sub is clearly inaccurate and unlikelyto represent the true consumption at the NMI, then theMDP must revise the sub. Again, in this circumstanceagreement of the FRMP, the LR and the LNSP is notrequired.

2.5.

Summary table ofSubstitution andEstimation Types

3 SUBSTITUTION FORMETERING INSTALLATION

The title of 2.3 should read “SUBSTITUTION FORMETERING INSTALLATIONS WITH REMOTE ACQUISITION



WITH REMOTEACQUISITION OFMETERING DATA

OF INTERVAL METERING DATA”.

3.1. Application of section 3

The title “3.1. Application of section 3” is not requiredand the words in the paragraph below could rest under“3.”

Regarding the obligation to “align with the adjoiningintervals” in section 3.1, the requirement to align subinterval values with the adjacent interval is relevant toLARGE customers, this is not a requirement which can beeasily complied with for mass market automated dataprocessing. It is the AusNet Services view that this isclearly inefficient and there should be differentialapproach for SMALL customers.

At the earlier workshop, it was agreed that use ofLARGE/SMALL as a process differentiator was difficult (forexample introducing changes as sites move above andbelow the LARGE/SMALL threshold) and that CT or directconnect was a reasonable alternative differentiator whichprovided a much more "black and white" criteria, albeitlikely in a small number of cases to require requirementsfor LARGE sites to be applied to smaller CT connectedcustomers.

The phrase "and that any intervals of metering dataadjacent to the Substituted period are valid" should beremoved as any non-valid intervals must be replaced bysubs in accordance with this Metrology Procedure.



In the interest of efficiency, AusNet Services stronglyrecommend replacement wording of “for allSubstitutions undertaken for CT connected meteringinstallations with remote acquisition of metering data,the MDP must ensure the selected Substitution valuescorrectly align with the adjoining intervals of meteringdata.”

3.2. Substitution Rules

AusNet Services has issues with the current proposedwording “the MDP must undertake to do a type 11Substitution and use metering data obtained from anycheck metering installation associated with theconnection point as the first choice considered for thesource of metering data for any Substitutionsundertaken.” In the AEMO workshop it was agreed thatthe use of the type 1-4 Sub methods for small customerremote read interval meters was inconsistent with thelevel of rigour and accuracy of subs applied to the currentmanually read (or in Victorian remote read) intervalmeters i.e. operated largely as type 5 meters. In thatmeeting, it was agreed that the current type 5substitutions Sub type 51 and 52 (Previous Year andPrevious Read) are much easier to automate for mass-market SMALL customers and should be the basis of theSubstitution Rules for these installations.

This agreement was reflected in the following clause hasbeen added at the end of Section 3 “for meteringinstallations installed under 9.9A, 9.9B and 9.9C of theNER, the MDP may also use Substitution types 51 and 52,which are detailed in section 4 of this Procedure.”



However, these NER clauses (the Victorian rolloutderogation) have been deleted in the MeteringContestability NER changes.

Hence, AusNet Services recommend the following newclause should be added, “The MDP may undertake to dotype 51 or type 52 Substitutions for Direct Connectedmetering installations or metering installations withMSATS Meter Installation Type Codes of VICAMI.” Wealso suggest that “Direct Connected” should be a definedterm in Glossary and Framework.

Furthermore, we recommend the details of type 51 and52 will need to be added to this Section (currently inSection 4 re MRIM). The clause after 3.2(c) will also needto be revised to “MDPs may only undertake Substitutiontypes 51, 52, 14, 15, 16, 17, 18, or 19 or 20 whereSubstitution types 11, 12 and 13 are not applicable orcannot be carried out.”

AusNet Services has issues regarding the followingproposed words and recommend the following changes.Firstly, we regard the agreement should be with allaffected retailers rather than FRMP. Secondly, wequestion the relevance of the MP’s agreement. “MDPsmay perform all Substitution types except type 16 or 18without the agreement of all affected FRMPs Retailers, orLNSPs or MPs. MDPs may change the quality flag to anexisting type 16 or 18 Substitution without seekingfurther agreement from those parties.”

We also recommend adding the following missing wordsin the next paragraph “MDP must notify the LNSP, LR and



the FRMP for the connection point of any Substitutionwithin two business days of the Substitution being carriedout by the MDP.”

AusNet Services has issues with the following paragraphsregarding in metering installation malfunction.

The remote acquisition system is not, beyond thecommunications interface at the meter, the roleof the MP but rather the MDP and hence theyshould be mentioned as a party to repairs.

The paragraph needs to reflect the requirementsin the NER 11.86.7 regarding a meteringinstallation malfunction to a LNSP meter underthe deemed MC arrangements. In this situationthe MC, MP and MDP (as specified in MSATS)have no role other than the LNSP as MC notifyingthe FRMP "promptly". The MC when appointed(promptly by the FRMP) then has 10 days to getan MP in place and to repair the MeteringInstallation.

subs must be provided within 2 days and hencethe reference of 10 days is NOT applicable to (a)below

Clause 3.2(a) should not be subject to the MCgranting an exemption to repair the meteringinstallation and it should read “where themetering installation malfunction is due to afailure of the meter to correctly record intervalenergy data, the MDP must Substitute the missingmetering data in accordance with this Procedure;”



3.3. Substitution Types

In relation to the Type 16 - Agreed Method substitution,it was agreed in the AEMO workshop that the use of thetype 1-4 Sub methods for Small customer remote readinterval meters was inconsistent with the level ofaccuracy of subs applied to the current manually read (orin Victorian remote read) interval meters ie type 5meters. Under this approach it is unnecessary to seekagreement after 15 days re the sub method for thesesmall (direct connected) installations.

AusNet Services considers the Type 16 – Agreed Methodshould therefore be “Where the MDP is required toundertake Substitution for any period greater than sevendays for type 1-3 metering installations or greater thanfifteen days for other CT Connected metering installationtypes…”

4

SUBSTITUTION ANDESTIMATION FORMANUALLY READINTERVAL METERINGINSTALLATIONS

In relation to the Type 20 – Churn Correction AusNetServices suggest “Where a MDP applies a type 19substitution following a Meter Churn and the previousMDP has not provided metering data for the start of theMeter Churn day as collected within the first week (orlonger period), the Current MDP may use the nearestequivalent day or like day, as detailed in table 1, andapply that metering data retrospectively to the start ofthe Meter Churn day.”


It is the AusNet Services view regarding the firstparagraph in 4.1 that there should be differentialapproach for SMALL customers, and hence for customerswhich are manually read. Whilst the requirement to align



sub interval values with the adjacent interval is relevantto LARGE customers, this is not a requirement, which canbe easily complied with for mass-market fully automateddata processing. Accordingly, AusNet Services considerthat this Clause should be removed from Section 4.

4.2.Substitution andEstimation Rules

4.3.Substitution andEstimation Types

In relation to the Type 55 – Agreed Substitution MethodAusNet Services suggest the following additional wordsto allow a Registered Participant to object to theagreement. “The MDP may undertake to use anothermethod of Substitution (which may be a modification ofan existing Substitution type), where none of the existingSubstitution types apply, subject to using reasonableendeavours to form an agreement with the FRMP, LR andLNSP for the connection point and where no partyobjects to the agreement. The specifics of thisSubstitution type may involve a globally applied method.

5

SUBSTITUTION ANDESTIMATION FORMETERINGINSTALLATIONS WITHACCUMULATEDMETERING DATA


5.2.Substitution and



Estimation Rules


In relation to the Type 64 – Agreed Substitution MethodAusNet Services suggest the following additional wordsto allow a Registered Participant to object to theagreement. “The MDP may undertake to use anothermethod of Substitution (which may be a modification ofan existing Substitution type), where none of the existingSubstitution types apply, subject to using reasonableendeavours to form an agreement with the FRMP, LR andLNSP for the connection point and where no partyobjects to the agreement. The specifics of thisSubstitution type may involve a globally applied method.

6

SUBSTITUTION ANDESTIMATION FORCALCULATED METERINGDATA

6.1. Substitution Rules


In relation to the Type 74 – Agreed Method AusNetServices suggest the following additional words to allow aRegistered Participant to object to the agreement. “TheMDP may undertake to use another method ofSubstitution (which may be a modification of an existingSubstitution type), where none of the existingSubstitution types apply, subject to using reasonableendeavours to form an agreement with the FRMP, LR andLNSP for the connection point and where no party



objects to the agreement. The specifics of thisSubstitution type may involve a globally applied method.

7

GENERAL DATAVALIDATIONREQUIREMENTS

7.1.

Validation requirementsfor all meteringinstallations

7.2.Validation of intervalmetering data alarms

Regarding 7.2 referring to Meter Alarms and the removalof "significant meter alarms". AusNet Services considerthat this wording should be retained, and/or referencemade to Section 7.2, which details this validation. Meteralarms can be a lot broader than just those related tometer validation.

8

VALIDATION WITHIN THEMETER READINGPROCESS

8.1.

Validations to beperformed duringcollection of meteringdata from manually readinterval meteringinstallations



8.2.

Validations to beperformed duringcollection of accumulatedmetering data

9VALIDATION AS PART THEREGISTRATION PROCESS

9.1.

Validation meteringinstallations with remoteacquisition of meteringdata

Regarding 9.1(a) AusNet Services consider that for themass of smaller customer installations the currentapproaches which are applied to type 5 and 6 metershave proven satisfactory and should be applied allmass-market meters. At an AEMO workshop in 2015 itwas agreed that the threshold should be defined on thebasis of customers with direct or CT connected meters.Whilst the contact between the MDP and the MP at thetime of commissioning of a metering installation is onlypotentially relevant for a large installation. The need forMPs whilst on site to install a mass-market metercontacting the MDP and exchanging metering data is notconsistent with the timeframes and cost associated withsmall customer meter churn and not justified by thevalue of consumption.

Hence we consider 9.1(a) should be revised to “(a) Thatthe metering installation that has been installed orchanged if CT connected is recording metering datacorrectly in conjunction with the MP.“

Regarding 9.1(e) AusNet Services considers this



statement is unclear and in any case it is unnecessary tocheck the expected magnitude and profile for the EndUser type, except in a commissioning test for a CTconnected meter in conjunction with the MP.

Regarding the paragraph in 9.1 pertaining to “meteringinstallations installed under 9.9A, 9.9B and 9.9C of theNER” AusNet Services consider, these clause and subclauses should be applicable to all whole current intervalmeter installations not just Vic AMI meters. Note thereference to 9.9 of the NER is no longer relevant as theseclauses were removed in the Metering Contestability NERchanges. These Validation must be carried out beforedata is delivered to Registered Participant for anypurpose not just for settlements e.g. for billing. Hencewe recommend changing the wording to “For wholecurrent metering installations MDPs must carry out thefollowing Validation prior to the distribution of anyinterval metering data to AEMO or RegisteredParticipants.”

Regarding the last line in 9.1 that in is incorrectly labelled(e) AusNet Services considers the NMI procedures allowNMIs to be re-allocated from one network to another,whilst these words indicate that a NMI with a differentnumber range is an exception. To resolve thisinconsistency that either changes are required to theMetrology Procedure Part B or the NMI Procedure.

9.2. Validation for manuallyread interval metering

Regarding the last line in 9.1 that in is labelled (e) AusNetServices considers the NMI procedures allow NMIs to bere-allocated from one network to another, whilst these



installations words indicate that a NMI with a different number rangeis an exception. To resolve this inconsistency that eitherchanges are required to the Metrology Procedure Part Bor the NMI Procedure.

9.3.

Validation for meteringinstallations withaccumulated meteringdata

Regarding the last line in 9.1 that in is labelled (e) AusNetServices considers the NMI procedures allow NMIs to bere-allocated from one network to another, whilst thesewords indicate that a NMI with a different number rangeis an exception. To resolve this inconsistency that eitherchanges are required to the Metrology Procedure Part Bor the NMI Procedure.

9.4.

Validation for meteringinstallations withcalculated metering data

10VALIDATION OFMETERING DATA

10.1. General

AEMO no longer appoints MDP. Replace with "EveryMDP providing metering data services must performValidation to ensure the quality and completeness of themetering data. AEMO may also request the MDPperform additional Validation to improve the quality andcompleteness of the metering data."

10.2. Validations to beperformed for all

Regarding 10.2(b)(ii) AusNet Services considers theproposed change from interval to TI is not required and



metering installations in any case TI is not defined in the Glossary andFramework.

10.3.

Validations to beperformed for meteringinstallations with checkmetering or partial checkmetering

Regarding 10.3(e) & (e)(i) this wording defined whatalarms must be used when available i.e. the "significantmeter alarms". AusNet Services consider that thiswording should be retained, and/or reference made toSection 7.2, which details this validation. Meter alarmscan be a lot broader than just those alarms related tometer Validation.

10.4.

Validations to beperformed for manuallyread interval meteringinstallations with CTs

Regarding 10.3(a),(b)&(c) AusNet Services considers theproposed change from interval to TI is not required andin any case TI is not defined in the Glossary andFramework.

10.5.

Validations to beperformed for wholecurrent manually readinterval meteringinstallations

Regarding 10.3(b) AusNet Services considers theproposed change from interval to TI is not required andin any case TI is not defined in the Glossary andFramework.

Regarding 10.5(c)(i) this wording defined what alarmsmust be used when available i.e. the "significant meteralarms". AusNet Services consider that this wordingshould be retained, and/or reference made to Section7.2, which details this validation. Meter alarms can be alot broader than just those related to meter validation.

10.6. Validations to beperformed for metering



installations withaccumulated meteringdata

10.7.

Validations to beperformed for meteringinstallations withcalculated metering data

11

LOAD PROFILING –CONVERSION OFACCUMULATEDMETERING DATA

11.1.Requirements for loadprofiling

11.2.

Profile PreparationService - Controlled LoadProfile

11.3.Basic Meter Profiler –Controlled Load

11.4.

Profile PreparationService - Net System LoadProfile



11.5.Basic Meter Profiler - NetSystem Load Profile

11.6. Start Dates and End Dates

12

UNMETERED LOADS –DETERMINATION OFMETERING DATA

12.1.Requirement to producecalculated metering data

12.2.Controlled UnmeteredLoads

12.3. Other unmetered loads

12.4. ON delay and OFF delay

12.5. Traffic signal dimming

13SUBSTITUTION FORTRANSFER

13.1. Application



13.2.Manually read intervalmetering installations

13.3.

Manually readaccumulation meteringinstallations



5. MSATS Procedures: CATS Procedure Principles and Obligations



General comments

AusNet Services believes the objection period of1 day for change requests is not long enough. Itdoes not allow for non NEM public holidays. Forexample in Victoria if a change request wasraised on Melbourne Cup Day by an interstateparticipant the Victorian participant will nothave enough time to object to the changerequest as the logging period would be overbefore they would have returned to work thenext business day.

AusNet Services suggest that the objectionlogging period should be 2 business days. Thiswill provide an adequate timeframe to covernon NEM public holidays.

QUICK REFERENCE GUIDE AusNet Services believe CR 6421 should eitherremain as is or change to Child NMI as this is



defined in the glossary. The heading for this CRhas not been change and is still the old heading.

HOW TO USE THISDOCUMENT

1 INTRODUCTION

1.1 PURPOSE AND SCOPE

1.2DEFINITIONS ANDINTERPRETATION

1.3COMMENCEMENT OFCHANGES

1.4 RELATED DOCUMENTS

AusNet Services believe this document is incorrectlynamed:

MSATS User Reference Interface Guide

2 OBLIGATIONS BY ROLE

2.1 GENERAL OBLIGATIONSAusNet Services believes that a general obligationaround objections should be included since it hasbeen removed from the specific role obligations.



Wording could be something like this:

A Participant may object to a change request byusing a valid objection code and adhering toobjection rules as per objection rules table for eachchange request.

(e) AusNet Service believes this clause is incompleteand does not make any sense.

Old (l) AusNet Services believes this clause should beretained as it provides clarity around how the MSATSsystem operates. This would be particularly usefulfor new entrant

2.2FINANCIALLY RESPONSIBLEMARKET PARTICIPANT

Old (a) AusNet Services questions why this has beenremoved. CATS is the procedure which enables thisobligation to be enacted. AusNet request that thisclause remain. This also ensures some consistencythat aligns with the obligations of the MC inappointing SP’s which has been included into theCATS procedures.

(s) AusNet Services believes there needs to betimeframes regarding this clause. If this notificationis not going to be via CATS then this needs to beremoved from the CATS procedure and ensured it’scaptured in the procedure that is going to providethese timeframes and notifications. If thenotification is going to be via MSATS then



timeframes need to be added to this clause. AusNetbelieves the time frame should be within 10 minutesof performing the action.

2.3LOCAL NETWORK SERVICEPROVIDER

(d) AusNet Services believes the reference in thisclause is incorrect and should be 17.13.2.

AusNet Services believe there should be two levelsof ‘re-en/de-en’ and it should be at NMI level whichthe LNSP is responsible for and the second should beat a meter status level which the service providershould be responsible for. This more correctly placesthe obligation on the actioning party and henceeliminates potential delays and handling errors.

Both of these statuses could sit at the NMI StandingData level. A new field on that table should becreated called Supply Contactor Status this fieldwould be controlled by the service provider. Thisallows the LNSP to just be responsible for thephysical status of the NMI. This removes theobligation on the LNSP to update a field to a statusthat they have no involvement in and can’t be 100%assured that the meter is actually remotelydisconnected or reconnected.

This would then mean that (k) and (m) wouldbecome a MP obligation to update the SupplyContactor Status to R or A.

Note that this does not eliminate the need for theDNSP to receive a notification to ensure that the



DNSP system is correct at all times and not justdriven by the delayed notification from MSATS.

2.4 LOCAL RETAILER

2.5 METERING DATA PROVIDER

2.6METERING PROVIDER –CATEGORY B

2.7 METERING COORDINATOR

AusNet Services believes this is a contractualagreement between the FRMP an d should not be anobligation on the MC.

(c) AusNet Services believes there needs to betimeframes regarding this clause. If this notificationis not going to be via CATS then this needs to beremoved from the CATS procedure and ensured it’scaptured in the procedure that is going to providethese timeframes and notifications. If thenotification is going to be via MSATS thentimeframes need to be added to this clause. AusNetServices believes the time frame should be within 10minutes of performing the action.

2.8 RETAILER OF LAST RESORT



2.9SECOND NETWORK SERVICEPROVIDER

2.10 AEMO

2.11EMBEDDED NETWORKMANAGER

3 CATS FUNCTIONALITY

3.1 OVERVIEW

3.2 PRINCIPLES

3.3 TRANSACTION TYPES

3.4 CHANGE REQUESTS

3.5CHANGE REQUEST STATUSLIFE CYCLE

3.6 TRANSACTION VALIDATION

3.7 VALID PROPOSED CHANGEDATE FOR PROSPECTIVE AND



RETROSPECTIVE CHANGEREQUESTS

4CATS CODES AND RULES FORA CHANGE REQUEST

4.1 INTRODUCTION

4.2 CHANGE REASON CODE

4.3 ROLE CODES

4.4CHANGE REQUESTINITIATION RULES

4.5 JURISDICTION CODES

4.6 TIMEFRAME RULES

AusNet Services has issues with the followinggrammar:

Whether the Change Reason Code can be used formake a Prospective Change or RetrospectiveChange;

Believe it should read

Whether the Change Reason Code can be used tomake a Prospective Change or RetrospectiveChange;



4.7 OBJECTION CODES

4.8 OBJECTION RULES

4.9 NMI CLASSIFICATION CODES

4.10 END USER CLASSIFICATION

4.11STATUS CODES (NMI ANDDATASTREAM)

AusNet Services question why the statement ‘Statuscode I must not be used as a NMI Status code’ has beenremoved from this section but not from section4.11.2. AusNet Services believe this statementshould remain to provide clarity to new participantswhen building their systems as there is not attechnical guide for CATS.

4.12METERING INSTALLATIONTYPE CODES

A large customer is defined in the in the NER as

large customer

(a) In a participating jurisdiction where the National EnergyRetail Law applies as a law of that participating jurisdiction,has the meaning given in the National Energy Retail Law.

(b) Otherwise, has the meaning given in jurisdictionalelectricity legislation, or a retail customer that is not a smallcustomer.



ie a non residential customer less than 40MWh pa.

However smart meters (type 4) with MSS capabilitieswill be installed on sites with greater than 40 MWhpa consumption. In fact where meters are installedat the FRMP choice (rather than due to meterfailure) these are more likely to be on largercustomers where the benefits to customer andretailer are greater.

Hence it is essential that the relevant parties seekingsmart meter services (eg distributors, or retailersseeking to make a transfer offer) understand the sitemeter capability.

The Metering Installation Type Codes as proposeddoes not facilitate this.

As proposed the following would apply:

COMMS4 Interval Meter with communications – Type 4(Note: This code is used for large customer with type 4metering installations and for small customer type 4 meteringinstallation installed before 1 December 2017)

COMMS4D Whole Current small customer meteringinstallation that meets the minimum services specifications

COMMS4C Current Transformer connected small customermetering installation that meets the minimum servicesspecification

MRAM small customer metering installation – Type 4A



VICAMI a relevant metering installation installed inaccordance with 9.9A, 9.9B, and as defined in clause 9.9Cof the NER clauses.

Hence a large customer (>40MWh pa) with ametering installation that meets the MinimumServices Specification will be indistinguishable from alarge customer installation which does not meet theMSS.

AusNet Services consider that the Type Codes shouldbe:

COMMS4 Interval Meter with communications –Type 4 (Note: This code is used for large and smallcustomer type 4 metering installations which do notmeet the minimum services specifications.

COMMS4D Whole Current large and smallcustomer metering installation that meets theminimum services specifications including large andsmall customer type 4 metering installation installedbefore 1 December 2017

COMMS4C Current Transformer connected largeand small customer metering installation that meetsthe minimum services specifications including largeand small customer type 4 metering installationinstalled before 1 December 2017

AusNet Services’ proposed Type Code approachachieves the outcome of having the installationcapability identified at Type Code level in MSATS.



Further the proposed approach removes the needfor Type Code changes as customers move above orbelow the small customer threshold.

4.13 READ TYPE CODE

AusNet Services believe read type codes of RR andSP should be made available to the meters that meetthe minimum spec. Currently VIC AMI use both ofthese codes. RR allows for a transfer the next timeyou read the meter, whether you read it daily orweekly or quarterly, SP allows for a customer tospecify a date they would like to transfer on.Applying SP to the min spec meters will allow theservice provider to read the meter on the specifieddate and complete the transfer. This could or couldnot be done in conjunction with a service request.

Not allowing these read types for the min specmeters may disadvantage customers (particularlythe ones who want to transfer on a specified date)

Table 4N is incorrect for VIC AMI NS, RR and SPshould be available at a minimum to VIC AMI, (NSbecause we have to provide a NSRD under the VICAMI spec) These could also be expanded to the newmin spec meters as per our previous comment.

Error correction in this table for NB this has a Yesagainst it for MRIM this is incorrect as it’s onlyavailable to Basic meters.

(h) AusNet Servicesbelieves this clauseshould be removed asit does not align withthe MRP. These readtype codes only areused for a FRMPtransfer and not ameter change. Asunder the rules thenew FRMP is onlyallowed to nominatenew roles (MDP, MPand MC) with themeter changing assoon as practical afterthe transfer of load.

We also believe withthe introduction of thisrule the read type codeof NI cannot be usedand should beremoved.

(j) We believe thisclause should be



reworded.

New wordingThe combinations ofRead Type Codes,Metering InstallationType Codes andChange Reason Codesthat can be valid,(provided the ReadType Code is allowedin a Jurisdiction), arespecified in Table 4-NT.(The MeteringInstallation Type Codereferred to here is thecode for the existingmetering record.) butthe metering installationtype may be beingchanged as part of thetransfer.)

4.14 FIELD VALIDATION RULES

4.15CHANGE REQUEST STATUSNOTIFICATION RULES

4.16MAINTENANCE OF CODESAND RULES

4.17 DATASTREAM STATUS CODE



4.18EMBEDDED NETWORKCODES AND RULES

4.19OBTAINING ELECTRONICDOWNLOADS OFCONFIGURATION RULES

Grammar:

Table 4P

Rule

Change Request Status Notification Rules the that specifywhich notifications are generated by MSATS

CATS_NOTIFICATION_RULES

5CODES AND RULES FOROTHER TRANSACTION TYPES

AusNet Services believes a reference to table 3Awould be relevant/helpful here particularly to newentrants as there is not a technical guide to MSATS.

A statement at the start of the section:

Refer to table 3A for all transaction types.

5.8 is incorrect we don’t believe you can commencea status, a status is an end point you cannot start astatus. We believe current wording is more accurate.

5.1SEND CHANGE REQUESTSTATUS NOTIFICATION

5.2 REQUEST PARTICIPANT DATA



5.3 RAISE OBJECTIONS

5.4WITHDRAW A CHANGEREQUEST

5.5 WITHDRAW AN OBJECTION

5.6REQUEST A NMI DISCOVERYSEARCH

5.7PROVIDE A NMI DISCOVERYSEARCH RESPONSE

5.8PROVIDE A CHANGEREQUEST RESPONSE

5.9PROVIDE AN OBJECTIONRESPONSE

5.10PROVIDE ANACKNOWLEDGMENT OF ATRANSACTION

5.11ADVISE OF AN UPDATE TO ACODE OR RULE



5.12 REQUEST A REPORT

5.13GUIDELINES FOR MANAGINGCONCURRENT RETAILTRANSFERS

5.14 AEMO BULK CHANGE TOOL

6CHANGE RETAILER – SMALLOR LARGE NMI

6.1APPLICATION [1000 10101020 1030 1040]

6.2 INITIATION RULES

The statement says:

a New FRMP may initiate a Change Request to effect achange of retailer by carrying out the following actions:

The table in h is a table of mandatory fields in MSATSso this table cannot sit under a statement that saysmay it needs to be a must.

Also to make it consistent with the rest of thedocument remove the Its’ in front of ParticipantID

(i) Is also a must not a may

6.3.3 We do not believe this clause is relevant for



this section. This is about the transfer of a FRMP notchanges to other roles. We suggest it should beworded to the effect of:

The new MC must:ensure MDP, MPC and MPB roles are correct andif not raise appropriate Change Request toupdate. Refer to section 29 to 36 for ChangeRequest types for Role Changes.

6.3 OTHER OBLIGATIONS

6.4 OPTIONAL REQUIREMENTS 6.4.2 covered in the must section using thesuggested wording.

6.5 TIMEFRAME RULES

6.6 OBJECTION RULES


7CHANGE RETAILER - ERRORCORRECTIONS –SMALL NMIS



7.1APPLICATION [1021 10221023 1024 1025 1026 10271028 1029]

7.2 CONDITIONS PRECEDENT


7.4 FRMP OBLIGATIONS

(d) to make it consistent with the rest of thedocument remove the Its’ in front of ParticipantID

7.5 MDP OBLIGATIONS

7.6METERING COORDINATOROBLIGATIONS

We do not believe this clause is relevant for thissection. This is about the transfer of a FRMP notchanges to other roles. We suggest it should beworded to the effect of:

The new MC must:

ensure MDP, MPC and MPB roles are correct andif not raise appropriate Change Request toupdate. Refer to section 29 to 36 for ChangeRequest types for Role Changes.

(c) can then be deleted as its covered in the new



wording

7.7 TIMEFRAME RULES

7.8 OBJECTION RULES


8CHANGE RETAILER –EMBEDDED NETWORKS –SMALL OR LARGE

8.1APPLICATION [1080 10811082 1083 1084]



8.4 FRMP OBLIGATIONS (e) to make it consistent with the rest of thedocument remove the Its’ in front of ParticipantID

8.5 MDP OBLIGATIONS




We do not believe this clause is relevant for thissection. This is about the transfer of a FRMP notchanges to other roles. We suggest it should beworded to the effect of:

The new MC must:


The new MC may is covered in the must section.

8.7 TIMEFRAME RULES

8.8 OBJECTION RULES

AusNet Services believe theLNSP (N) should have anability to object to the changerequest in the case of beingallocated incorrectly. Eg theENM selects the incorrectLNSP participant id.


9PROVIDE DATA – PROVIDEACTUAL CHANGE DATE –SMALL OR LARGE



9.1 APPLICATION [1500]



9.4 MDP OBLIGATIONS

9.5 TIMEFRAME RULES

9.6 OBJECTION RULES


10CREATE NMI – CREATE ANMI – SMALL OR LARGE

10.1APPLICATION [2000 20012003]





10.4 LNSP Obligations

10.5 MPB OBLIGATIONS

10.6 TIMEFRAME RULES

10.7 OBJECTION RULES


11CREATE NMI – CREATE CHILDNMI - SMALL OR LARGE

11.1 APPLICATION [2020 2021]



11.4 ENM Obligations






AusNet Services believe theLNSP (N) should have anability to object to the changerequest in the case of beingallocated incorrectly. Eg theENM selects the incorrectLNSP participant id.


12

CREATE NMI – CREATE NMI,METERING INSTALLATIONDETAILS AND MDMDATASTREAM – SMALL ORLARGE

12.1 APPLICATION [2500 2501]









Old 13

CREATE NMI – CREATE NMI,METERING INSTALLATIONDETAILS AND MDMDATASTREAM FOREMBEDDED NETWORK(CHILD)– SMALL OR LARGE

AusNet Services question whythis was deleted. This could beused by the ENM if they hadall of the information required.If the answer is they can usethe CR2500/01 then thatneeds to be made clear in thatsection.

13

MAINTAIN METERING –CREATE METERINGINSTALLATION DETAILS –SMALL OR LARGE

13.1APPLICATION [3000 30013003]





13.4 MPB Obligations

AusNet Services do not agree with the making of thisfield mandatory for the MPB. The MPB does nothave the understanding of Network tariffs that theLNSP does and cannot be held responsible for aNetwork tariff. There isn’t any obligations on theLNSP to provide the Network tariff to the MPB.

AusNet Services believe that updating of informationshould sit with the participant that has theobligation. We also believe that the Network tariffshould sit at NMI level and not metering level.




14

MAINTAIN METERING –EXCHANGE OF METERINGINFORMATION – SMALL ORLARGE

14.1 APPLICATION [3004 3005]

Incorrect statement

Should read:

3005 – Exchange of Metering information –Retrospective



This is where the Current MPB is required to providea Prospective Respective Change to the informationin MSATS in regard to the metering installationdetails. The change will include the removal of at leastone existing meter and the installation of at least onenew meter. A minimum set of metering installationdetails for the NMI shall exist upon completion of theChange Request.











15

MAINTAIN METERING –CHANGE METERINGINSTALLATION DETAILS –SMALL OR LARGE

15.1APPLICATION [3050 30513053]











16

MAINTAIN METERING -ADVANCED CHANGEMETERING INSTALLATIONDETAILS - SMALL OR LARGE

16.1 APPLICATION [3080 3081]



16.4Metering CoordinatorObligations






17

MAINTAIN METERING -ADVANCED EXCHANGE OFMETERING - SMALL ORLARGE

17.1 APPLICATION [3090 3091]



17.4Metering CoordinatorObligations




18 MAINTAIN METERING –



CHANGE NETWORK TARIFFCODE – SMALL OR LARGE

18.1 APPLICATION [3100 3101]







19MAINTAIN DATASTREAM –CREATE MDM DATASTREAM–SMALL OR LARGE

19.1APPLICATION [4000 40014003]





19.4 MDP Obligations




20

MAINTAIN DATASTREAM -EXCHANGE OF DATASTREAMINFORMATION SMALL ORLARGE

20.1 APPLICATION [4004 4005]









21

MAINTAIN DATASTREAM –CHANGE MDMDATASTREAM – SMALL ORLARGE

21.1APPLICATION [4050 40514053]









22MAINTAIN NMI – UPDATENEXT SCHEDULED READDATE – SMALL OR LARGE

22.1 APPLICATION [5070 5071]









23MAINTAIN NMI – BACKDATEA NMI – SMALL OR LARGE

23.1 APPLICATION [5001 5021]



23.4LNSP OBLIGATIONS (5001ONLY)

23.5ENM OBLIGATIONS (5021ONLY)

23.6 AEMO OBLIGATIONS




23.10 CHANGE REQUEST STATUS



NOTIFICATION RULES

24MAINTAIN NMI – CHANGE ANMI – SMALL OR LARGE

24.1APPLICATION [5050 50515053]






The table 24A shows 0 objection logging days butthe Objection Rules table allows some objections.

AusNet Services believe there should not be anyobjections on these change requests


25 MAINTAIN NMI – CHANGE A



NMI - CUSTOMERCLASSIFICATION CODE –SMALL OR LARGE

25.1 APPLICATION [5054 5055]



25.4 FRMP Obligations




26MAINTAIN NMI – CHANGENMI EMBEDDED NETWORK(CHILD) – SMALL OR LARGE

26.1 APPLICATION [5060 5061]






Incorrect statement

Should state:

The Current LR ENM may




27MAINTAIN NMI – CHANGEPARENT NAME – SMALL ORLARGE

27.1 APPLICATION [5080 5081]






27.5 LNSP OBLIGATIONS




28MAINTAIN NMI – MAKE NMIA CHILD NMI – SMALL ORLARGE

28.1 APPLICATION [5090 5091]









29CHANGE ROLE – CHANGELNSP – SMALL OR LARGE

29.1 APPLICATION [6100 6110]









30CHANGE ROLE – CHANGEMDP – SMALL OR LARGE

30.1 APPLICATION [6200 6210]








31CHANGE ROLE – CHANGEMETERING COORDINATOR –SMALL OR LARGE



31.1 APPLICATION [6300 6301]



31.4METERING COORDINATORObligations




32CHANGE ROLE – CHANGE LR– SMALL OR LARGE

32.1 APPLICATION [6300 6301]





32.4 LR Obligations




33CHANGE ROLE – CHANGE LR- EMBEDDED NETWORK(CHILD) – SMALL OR LARGE

33.1 APPLICATION [6421]

AusNet Services believe thisCR could also be used by theENM to ensure the standingdata in MSATS is correct. Thiswill allow both parties toupdate this information.



33.4 LR Obligations






34CHANGE ROLE – CHANGEROLR – SMALL OR LARGE

34.1 APPLICATION [6500 6501]



34.4 ROLR Obligations


34.6 OBJECTION RULES Statement says no objection rules permitted but thetable 34A allows objection logging periods.

34.7 CHANGE REQUEST STATUS Are the rules in the notification tables going tochange for this? Some participants may have built



NOTIFICATION RULES their systems to accept these as a RoLR particularlyin VIC where we have not adopted NECF. As the newand current wouldn't you want to know the status.

35CHANGE ROLE – CHANGEMPB OR MPC– SMALL ORLARGE

35.1 APPLICATION [6700 6701]







36 CHANGE ROLE – CHANGEMULTIPLE ROLES – SMALL



OR LARGE

36.1 APPLICATION [6800 6801]





36.6 MDP OBLIGATIONS




37AUTO CHANGE ROLE –CHANGE LOCAL RETAILEREMBEDDED NETWORK CHILD



– SMALL OR LARGE

37.1 APPLICATION [ECLR]





38AUTO CHANGE ROLE –CHANGE SECONDARY FRMPPARENT – SMALL OR LARGE

38.1 APPLICATION [EPFR]







39AEMO ONLY - AEMO-INITIATED STANDING DATAUPDATES – SMALL OR LARGE

39.1 APPLICATION [5100 5101]



39.4 AEMO Obligations




40AEMO ONLY - CHANGE ROLE,TNI OR DLF CODE – BULKCHANGE TOOL (BCT) –



SMALL OR LARGE

40.1 INTRODUCTION


40.3REQUESTING PARTICIPANTOBLIGATIONS

40.4IMPACTED PARTICIPANTOBLIGATIONS

40.5 MDP OBLIGATIONS




41ACCESS TO CATS STANDINGDATA

41.1 INTRODUCTION



41.2 PARTICIPANT

41.3NMI DISCOVERY SEARCH 1 –NMI SEARCH RULES

41.4NMI DISCOVERY SEARCH 2 –NMI STANDING DATAACCESS RULES

Corrections and additionsto 41C table

Parent Name

A code representing thename of an ENM a parentconnection point.

LNSP

A code representing theidentity of the LNSP orEmbedded NetworkManager for a childconnection point

41.5CATS STANDING DATAACCESS RULES

Addition to 41G table

LNSP

Current Local Network ServiceProvider or EmbeddedNetwork Manager for a childconnection point



41.641.6 NMI DISCOVERYSEARCH 3 – NMI STANDINGDATA ACCESS RULES



6. MSATS Procedures: MDM Procedures



1 INTRODUCTION




AusNet Services believe the CATSprocedures should also be included in thislist.

This document is incorrectly named:


With the removal of 1.7 all relevant use ofthe word day should be in italics as it’s adefined definition in chapter 10 of the NER.



2 OBLIGATIONS

2.1 General Obligations

2.2 AEMO

3 MDM FUNCTIONALITY

3.1 Introduction

3.2 Setup Functionality

4MAINTENANCE OF TNI ANDPROFILE AREA

4.1 Introduction

4.2 Create a Profile Area

4.3Maintain Profile AreaAttributes



5LOAD DATA – NON-INTERVAL NMI DATASTREAM

5.1 Conditions Precedent

AusNet Services believe that if the belowclause is being remove then 5.2 needs tohave active in front of it. Refer to 5.2

A non interval NMI Datastream already exists in CATSwith active status. If the Datastream does not exist itmust first be defined in CATS (refer CATS Procedures)before this procedure can be implemented.

5.2 MDP Obligations

AusNet Services believes that the openingsentence should state

For any active non-interval NMI Datastream inCATS, the

6LOAD DATA – INTERVAL NMIDATASTREAM

6.1 Application

6.2 Conditions Precedent AusNet Services believe that if the belowclause is being remove then 6.2 needs to



have active in front of it. Refer to 6.2

An interval NMI Datastream already exists in CATS withactive status. If the Datastream does not exist it mustfirst be defined in CATS (refer CATS Procedures) beforethis procedure can be implemented.

6.3 MDP Obligations

AusNet Services believes that the openingsentence should state

For any active interval NMI Datastream in CATS,the

6.4Load Sample Meter Data forDefined NMI Datastreams

6.5Load Externally CalculatedProfile Shape

7 DEFINE PROFILE

7.1 ApplicationAusNet Services question the reason forleaving this section in when other sectionshave had this type of information removed.

7.2 Define the Data Source



7.3 Define the Profile Method

7.4 Define the Profile Name

8 PROFILE CALCULATION

8.1 ApplicationAusNet Services question the reason forleaving this section in when other sectionshave had this type of information removed.

8.2 Settlement Data Scenario

8.3 Settlement Data Cases

9 REPORTS

9.1 IntroductionThis document is incorrectly named:


9.2 Report Outlines

AusNet Services believe for:

RM13 need to have the ENM and MC addedlike it has been for the RM15 report.



APPENDIXA

MDM DATA LOADTRANSACTION PROCESS



7. MSATS Procedures: Procedure for the Management of Wholesale, Interconnector,Generator and Sample (WIGS) NMIs

Clause Heading

Participant Comments


General Comment AusNet Services believe the formatting of thedocument and tables to be consistent through thewhole document.

1 Introduction



1.3Commencement ofChanges

1.4 Related DocumentsIncorrect document name


Old 1.10 & Jurisdictions and NMI AusNet Services believe these sections should remainas some participants who use WIGS have no need to



1.11 Classification Codes refer to the CATS procedures. These should be left infor ease of use, instead of having to go to anotherdocument to obtain this information.

2Change FRMP - ChangeFRMP

2.1. Application [1000 1020]

2.2. Conditions Precedent

Extra wording

(b) The NMI Classification Code is WHOLESAL,INTERCON, GENERATR , or SAMPLE.ChangeReason Codes.

2.3. Initiation Rules

Correction

A New FRMP may initiate a Change Request tomake the change.

2.4. Obligations

2.4.2 This information was removed in the CATSversion. Please remove this or add to CATS forconsistency

2.4.4 We do not believe this clause is relevant for thissection. This is about the transfer of a FRMP notchanges to other roles. We suggest it should beworded to the effect of:

The new MC must:



ensure MDP, MPC and MPB roles are correct and ifnot raise appropriate Change Request to update.Refer to section 21 to 27 for Change Requesttypes for Role Changes.


2.4.5 This information was removed in the CATSversion. Please remove this or add to CATS forconsistency

2.5.2 may is covered in the must section.

2.5. Rights

2.6. Timeframe Rules

2.7. Objection Rules

2.8.Change Request StatusNotification Rules

3Change FRMP – EmbeddedNetworks – generator andwholesale

Needs to be at the start of a page.

3.1. Application [1080,1082]





3.4. FRMP Obligations Keep it consistent with CATS and just haveParticipantID

3.5. ENM(LNSP) ObligationsCorrection:

The Current ENLR ENM may:

3.6. MDP Obligations

3.7. RP(MC) Obligations

3.7 We do not believe this clause is relevant forthis section. This is about the transfer of a FRMPnot changes to other roles. We suggest it shouldbe worded to the effect of:

The new MC must:





3.8. TimeFrame Rules


AusNet Servicesbelieve the LNSP(N) should have anability to object tothe change requestin the case of beingallocatedincorrectly. Eg theENM selects theincorrect LNSPparticipant id.


4Provide Data – ProvideActual Change Date

4.1. Application [1500]






4.5. Time Frame Rules



5CREATE NMI - Create aNMI Needs to be at the start of a page.

5.1. Application [2000 2001]



5.4. LNSP Obligations

5.5. MPB Obligations






6CREATE NMI – Create NMIEmbedded Network (child)– wholesal and generatr

6.1. Application [2020 2021]



6.4. ENM Obligations




6.8. Change Request Status



Notification Rules

7

CREATE NMI – Create NMI,metering installationdetails and MDMDatastream

7.1. Application [2500 2501]







8Maintain Profile Shapes –Create and ChangeExternal Profile Shape



8.1.Application [2100 21015110 5111]



8.4. AEMO Obligations


Timeframe rules state there is 1 day objectionlogging period.

Objections rules state no objections permitted.

AusNet Services believe there should be noobjections.



9Maintain Metering –Create MeteringInstallation Details



9.1. Application [3000 3001]




AusNet Services do not agree with the making of thisfield mandatory for the MPB. The MPB does not havethe understanding of Network tariffs that the LNSPdoes and cannot be held responsible for a Networktariff. There isn’t any obligations on the LNSP toprovide the Network tariff to the MPB.

AusNet Services believe that updating of informationshould sit with the participant that has the obligation.We also believe that the Network tariff should sit atNMI level and not metering level.



9.7Change Request StatusNotification Rules

10 Maintain Metering –EXCHANGE OF METERING



information

10.1. Application [3004 3005]



10.4. MPB obligations








11Maintain Metering –Change MeteringInstallation Details

11.1. Application [3050 3051]








11.7. Change Request Status



Notification Rules

12Maintain Metering –Change Network TariffCode

12.1. Application [3100 3101]




12.5. Time Frame Rules



13Maintain Datastream –Create MDM Datastream

13.1. Application [4000 4001]









14Maintain datastream -Exchange of Datastreaminformation

14.1. Application [4004 4005]



14.4. MDP obligations






15Maintain Datastream –Change MDM Datastream

15.1. Application [4050 4051]









16Maintain NMI – backdate aNMI

16.1. Application [5001, 5021]




16.5.ENM(LNSP) Obligations(5021 only)








17Maintain NMI – Change aNMI

17.1. Application [5050 5051]






Timeframe rules state 0 days for objection loggingperiod but the objection rules show who andwhat objections can be made.

AusNet Services believe no objections should beon this CR


18Maintain NMI – ChangeNMI Embedded Network(child) – WHOLESAL or



generator

18.1. Application [5060 5061]



18.4. ENM (LNSP) Obligations




19Maintain NMI – ChangeParent Name – generatoror wholesale

19.1. Application [5080 5081]





19.4. FRMP Obligations





20Maintain NMI – make nmia child nmi –

20.1. Application [5090 5091]









21Change Role – ChangeLNSP

21.1. Application [6100 6110]









22Change Role – ChangeMDP

22.1. Application [6200 6210]



22.4. FRMP Obligations

22.5. RP Obligations




23 Change Role – Change RP

23.1. Application [6300 6301]









24 Change Role – Change LR

24.1. Application [6400 6401]



24.4. LR obligations






25

CHANGE ROLE – CHANGELR – EMBEDDED NETWORK(CHILD) – GENERATOR andwholesale

25.1. Application [6421]



25.4. LR Obligations






26Change Role – ChangeROLR

26.1. Application [6500 6501]



26.4. ROLR Obligations

26.5. TimeFrame Rules



27Change Role – ChangeMPB AND / OR MPC

27.1. Application [6700 6701]









28AEMO ONLY - AEMO-initiated standing dataupdates

28.1. Application [5100 5101]









29AEMO ONLY – CHANGE -ROLE, TNI OR DLF – BULKCHANGE TOOL (BCT)

29.1. Introduction



29.4.Requesting ParticipantObligations

29.5.Impacted Participant/sObligations







30

AUTO Change Role –Change local retailerembedded network child –generator and wholesale

30.1. Application [ECLR]





31

AUTO Change Role –Change secondary FRMPembedded network parent– generator and wholesale



31.1. Application [EPFR]





8. NEM RoLR Process Part A and B – MSATS Procedure: RoLR Procedures



1 INTRODUCTION

AusNet Services observed that the entire Part B(sections 101 to 105) is missing the necessary changesto conform to the new Procedure drafting and to alignwith Rule changes. These sections require updating



even if only to update inconsistent terminology.



1.3 Related DocumentsAusNet Services suggest adding references to the B2BProcedures and the MP and MDP SLP.

2 Summary of ROLR Processes

2.1 Preconditions

3 REPORTS

4General MSATSOBLIGATIONS

4.1 Application

4.2General Obligations forMSATS Participants

4.3 AEMO



4.4 Failed Retailer

5AEMO Notifies ROLR KeyContacts FollowingSuspension of a Retailer


In relation to5.1(a)(i)(C) AusNetServices considerthe ENM must alsobe included in theannouncement.

5.2ROLR Affected MSATSParticipant Obligations

6AEMO Produces and DeliversSummary ROLR Reports


6.2ROLR Affected MSATSParticipant Obligations

7 AEMO Produces and Delivers



NMI List Reports


7.2ROLR Affected MSATSParticipants

7.3 Time Frame Rules

8AEMO Cancels Transfers inProgress to the SuspendedRetailer


9

AEMO Cancels Other MSATSChange Requests in ProgressInitiated by the FailedRetailer

9.1 Obligations

10AEMO Accelerates Transfersin Progress from theSuspended Retailer





11AEMO Changes the FRMP forSecond Tier NMIs from theFailed Retailer




12AEMO Changes the LR forSecond Tier NMIs from theFailed Retailer






13

AEMO Changes FRMP and LRRoles for First Tier NMIsfrom the Failed Retailer andCompletes Other RoleChanges as Required

13.1 ApplicationThe word “failed” was inadvertently added in 13.1(b)as part of a find and replace. We suggest it isremoved.


The word “is” was inadvertently removed in 13.2(c)and should be reinstated.

The word “failed” was inadvertently added in 13.2(d)as part of a find and replace. We suggest it isremoved.

13.3 AEMO ObligationsThe word “failed” was inadvertently added in13.3(c)(ii), (d)(iv), (e), (g) and (i)(iv) as part of a findand replace. We suggest it is removed.


14AEMO Produces PendingTransfer Request and ROCTransfer Confirmation Email



for the ROLR


14.2 ROLR Obligations


15MDP Provides Metering Datato MSATS for ROLR EffectiveTransfer Date




15.4 Related Part B Section

16AEMO Changes ROLR Role inMSATS from the FailedRetailer






17AEMO Ceases all the FailedRetailer’s Roles as of ROLREffective Transfer Date




18

Participants Perform a PostROLR Event Reconciliation ofMSATS-Related Data andPrepare a Report for AEMO




18.2ROLR Event Affected MSATSParticipants Obligations

In relation to the last row 18.2 Table 15 AusNetServices considers it incorrectly indicates that theFRMP assigns the MDP. The MC under the new Rulesappoints both the MDP and the MPs. We suggestmoving MDP cells to the above MC row.


18.4 Related Part B Section

19AEMO CONDUCTS ROLRPOST IMPLEMENTATIONREVIEW


APPENDIX- 1

SPECIFICATIONS FOR ROLRREPORTS



9. NMI Standing Data Schedule


Metering Competition Embedded Networks Meter Replacement Processes

1 INTRODUCTIONAusNet have no comments forthis document.




2NMI STANDING DATASCHEDULE

3 RIGHTS AND OBLIGATIONS

3.1Obligations to supply datafor the NMI Standing DataSchedule



3.2Obligations when using theNMI Standing Data Schedule

4AMENDMENT TO THISDOCUMENT



10. Service Level Procedures for MDP


Metering Competition EmbeddedNetworks

Meter ReplacementProcesses

1 INTRODUCTION



1.3 Related DocumentsAusNet Services believes that the MDFF Procedure andSpecial Sites document should be included in this list.

2 OBLIGATIONS

2.1 Metering data services

AusNet Services believe that e) should be retained butwith this wording

maintain security of systems capable of remotely reading meteringdata and of remote re-energisation and de-energisation



new d) should be reworded to

undertake the collection, processing and delivery of metering data andrelevant MeterAlarm occurrences, through the processes for which the MDP hasbeen accredited and engaged;

As Meter Alarms can potentially be a broad category ofoccurrences. Not all alarm information collected fromthe meter is relevant to a retailer or DNSP.Other option is to update the glossary definition to:

Meter AlarmAny significant alarm situated within a metering installation designed todetect any unexpected occurrence, such as a loss of supply, VT orphase failure, tamper detection, reverse energy flow, pulse overflow,cycle redundancy check error and temperature or time tolerance.

Current proposed drafting:

"....cooperate in good faith ...."

The concept of an obligation to "cooperate in goodfaith" is very imprecise obligation. The specificobligations for the MDP should be defined in the NERand Procedures and this broad generic catchallrequirement to "cooperate" should be removed.

Current proposed drafting:



(g) In regard to connection points that are affected by aRoLR Event, or where a Jurisdiction has requestedAEMO to undertake End User transfers, the MDP must:(h) assist AEMO and Registered Participants with themanagement of transfers;(i) process and deliver metering data; and(j) update the metering register and relevant CATSStanding Data.

Suggested rewording:

* (h) (i) (j) are subclauses of (g) and hence should besuitable numbered below (g)

* (h) reads: " assist AEMO and Registered Participantswith the management of transfers" The concept of anobligation to "assist with management of transfers" isvery imprecise obligation. The specific obligations forthe MDP for ROLR should be defined in the ROLRProcedure, and this broad generic requirement to"assist" should be removed.

2.2 Use of sub-contractors

2.3Specific obligations for MDP- Category D

Clause i)

AusNet Services believe that MDP’s should have theoption of making datastreams inactive when the NMIhas been de-energised as well as the 2 scenariosprovided. Some MDP’s may prefer to inactivate their



datastreams instead of leaving them active and sendingzero data.

New wording:

i) only deactivate Datastreams in MSATS:(i) where the NMI has been abolished and there is no continuedmetering data beingrecorded for the connection point;(ii) where the connection point has moved within an embeddednetwork and is not a childconnection point; or

(iii) in accordance with section 5 .

The MDP may deactivate datastreams when the NMI has been de-energised, either remotely or physically.


Where the metering installation includes themeasurement of reactive energy, the MDP must storethis metering data with the metering data in respect ofactive energy in the metering data services database.

AusNet Services consider that there should not be alinkage between the measurement of reactive in themeter and the storing of reactive in the meter dataservice data base. Whereas a smart interval metermust have the capability to measure reactive (and alsogeneration) the base level requirement is for the storingin the meter, retrieval, and handling and storage in themeter data service data base of active energy data. Thestoring in the meter, retrieval, and handling and storagein the meter data service data base of reactive energydata (or generation data) is at the request of the



relevant market participants. It is in no ones interest toadd additional storage and retrieval capacity to theMDP systems for reactive data which is of no interest tothe market participants.

Further the phrase "with the metering data in respectof active energy" is not understood and should berevised or removed.

Hence this clause should be revised to read:

Where the metering installation includes themeasurement of reactive energy, the MDP at therequest of a Participant must store this metering datain the metering data services database.

2.4Specific obligations for MDP- Category C

3SERVICE REQUIREMENTSFOR MDPS – CATEGORY D

3.1 System requirements

AusNet Services believes this should state:

l) Significant Meter Alarms

As Meter Alarms can potentially be a broad category ofoccurrences. Not all alarm information collected fromthe meter is relevant to a retailer or DNSP.



Other option is to update the glossary definition to:

MeterAlarm

Any significant alarm situated within a meteringinstallation designed to detect any unexpectedoccurrence, such as a loss of supply, VT or phase failure,tamper detection, reverse energy flow, pulse overflow,cycle redundancy check error and temperature or timetolerance.

3.2Collection processrequirements

3.3

Specific collection processrequirements for meteringinstallations type 1, 2, 3 and4

Current proposed wording of heading:

3.3. Specific Collection Process Requirements forMetering Installations Type 1, 2, 3 and 4

However the metrology suite of document has beenwritten, correctly AusNet Services believe, so that thetype of a Vic AMI meter is NOT specified and hence itcould be a type 5 or a type 4. This is consistent with theNER and consistent with an effective and efficientapproach for the mass of Victorian AMI meters.

Hence this Section should deal with the following:



3.3. Specific Collection Process Requirements forremote read Metering Installations

3.4Specific collection processrequirements for meteringinstallations type 4A, 5 and 6

Current proposed wording of heading:

3.4. Specific Collection Process Requirements forMetering Installations Type 4A, 5 and 6

However the metrology suite of document has beenwritten, correctly AusNet Services believe, so that thetype of a Vic AMI meter is NOT specified and hence itcould be a type 5 or a type 4. This is consistent with theNER and consistent with an effective and efficientapproach for the mass of Victorian AMI meters.

Hence this Section should deal with the following:

3.3. Specific Collection Process Requirements for



manually read Metering Installations

3.5Metering data processingrequirements

AusNet Services believe that

b) support the receipt and actioning of Provide and Verify Meter DataRequests in accordance with the B2B Procedures;

Should be retained as Removing MDP obligationsassociated with PMDs and VMDs weakens the rights ofLRs and DNSPs from requesting missing data from aMCs engaged MDP.Current proposed wording:

Where any {Registered Participant for the connectionpoint = Deleted} FRMP disputes metering data, therelevant MDP must investigate, and if necessary correctthe metering data in accordance with the MetrologyProcedure: Part B.

However the original wording which allowed partiesother than the FRMP to dispute the metering data (egthe DNSP) should be retained.

Further the concept in the B2b Procedure Meter Datawhich utilises an MDV Transaction is not a "dispute" asgenerally recognised in the Rules (ie subject to theDispute Provisions in the NER) but rather a request toreview and replace as necessary metering data.

Suggested wording:



Where any Registered Participant for the connectionpoint requests review of the metering data, therelevant MDP must investigate, and if necessary correctthe metering data in accordance with the MetrologyProcedure: Part B.

3.6

Specific Metering Dataprocessing requirements formetering installation types 1,2, 3 and 4

AusNet Services has issues with the followinggrammar/spelling:

The MDP must operate in accordance section 5

Should read

The MDP must operate in accordance with section 5

3.7Specific Metering Dataprocessing requirements forSpecial Sites

3.8Specific Metering Dataprocessing requirements formetering installation type 7

3.9Specific Metering Dataestimation requirements formetering installation types



4A, 5, 6 and 7

3.10Delivery performancerequirements for meteringdata

Current proposed wording :

Subject to any agreement to the contrary ascontemplated by section 8.1, each MDP must:(a) deliver to AEMO, the New MDP when there hasbeen a Meter Churn and Registered Participants allActual Meter Readings that passed Validation withintwo business days of the Actual Meter Readings beingreceived into the metering data services database;(b) Substitute, Validate and deliver to AEMO, the NewMDP when there has been a Meter Churn andRegistered Participants the substituted metering datawithin two business days of the Actual Meter Readingsbeing received into the metering data services databaseand failing Validation; and(c) Substitute, Validate and deliver to AEMO, the NewMDP when there has been a Meter Churn andRegistered Participants the substituted metering datawithin two business days of the receipt of any faultreason codes associated with a reading failure or failedinterrogation event, into the metering data servicesdatabase.

However this clause and subclauses:

* fails to recognise that the metrology for the 2.5million AMI meters in Victoria have a clear obligationfor metering data to be provided at specified levels ofcompleteness and actual data by 6 am of the day afterthe "data day" (and various other level of actual data



over longer periods). AusNet Services consider that thiscritical aspect of the metrology requirements must bespecified in the SLP and not left orphaned in theVictorian Service Level Specification.

* appears to have been drafted with littleconsideration of the broad industry minimummetrology requirements for the scheduled readingsfrom MSS compliant meters (the New and Replacementmeters under the Metering Contestability framework)which potentially could be more stringent that the twobusiness days currently specified.

Apart from some industry opinion sought during theAEMO drafting of SMP Advice to COAG this aspect ofthe metrology framework has been given littleconsideration.

AusNet Services believe timetable is not the correctterm to be used here and would prefer Data DeliveryCalendar remain. We don't believe the definitionsunder the rules for timetable is specific enough for anynew participant to have clarity on what this meanswhen it comes to data delivery. Data delivery's primefunctionality is for settlements not really the running ofthe spot market.Suggest Data Delivery Calendar is included in theglossary

Reword:(g) deliver metering data to Registered Participants in



accordance with this Procedure by delivering themetering data to the B2B e-Hub in the MDFF or via analternative method and in the format agreed; and

3.11Delivery of Metering Datafor Prudential Purposes

AusNet Services believes Eastern Standard Time needsto be retained as this provides clarity to new MDP’s thatthe request will be sent by EST and not Local time andmetering data must be delivered by 8am EST not localtime.

Make this consistent:

(b) 80% complete data set of Validated metering data for allconnection points, consisting of

Actual metering data, substituted metering data or estimated meteringdata.

3.12 Interface requirements

AusNet Services question why LNSP’s have been singledout in this clause. LNSP’s are registered participants.Remove other LNSP’s. If this is meant to cater for ENM’sthen maybe ENM is better placed in this clause.

(b) the B2B e-Hub for the interface with Registered Participants, otherLNSPs, MPs and for the delivery of metering data to RegisteredParticipants and other MDPs; and

AusNet Services believe that instead of removing theclause regarding the active line of communication itcould be worded as such:Each MDP may:- maintain an ongoing active line of communication with the B2B e Hubfor the management and response to B2B e Hub requests andnotifications- transact through the B2B e Hub interface and comply with therequirements of the aseXML message size requirements and B2B



Technical Delivery Specification.

4SERVICE REQUIREMENTSFOR MDPS - CATEGORY C

4.1 System Requirements

4.2Metering Data Collectionand Transfer Requirements

5METER CHURN DATAMANAGEMENT

5.1 Meter churn scenarios

AusNet Services believe the removal of 30 minute fromScenario 4 (v) could lead to uncertainty for new MDP’s.For clarity this should be left in this clause. AusNetServices understand that it’s a requirement statedpreviously in this procedure but believe having it in thisclause as well will remove any uncertainty whenprocessing churn data.

6SYSTEM ARCHITECTURE &ADMINISTRATION

6.1Metering Data Archival andRecovery



6.2 Data Backup

6.3 Disaster Recovery

6.4System administration anddata management

6.5Non-publictelecommunicationsnetworks

7 QUALITY CONTROL

7.1 Scheduled Audits

7.2 Other audits

7.3 Corrective action

7.4Non-compliance and de-registration

7.5 Review of accreditation



8 ADMINISTRATION

8.1 Bilateral agreements

8.2 Quality systems

8.3 Disputes



11. Service Level Procedures for MP

Clause Heading

Participant Comments


1 Introduction


1.2 Definitions and Interpretation


2 General requirements

2.1Metering Provider Capabilityand Competency

Regarding 2.1(c) AusNet Services considers basingpolicies and procedures on opinions documentedwithin the quality systems does not represent robustquality management. Instead we suggest policiesand procedures should reference regulatoryrequirements and business requirements.

In relation to 2.1(d) AusNet Services regards thatLSNP requirements are either applicable generally to



a MP or they are not applicable. For example, theService Installation Rules (SIRs) in every jurisdictionrepresent the agreed best practice with thejurisdictions safety regulator. Unless AEMO draftsnational SIRs in the interest of safety, then the MPBService Level Procedure should mandate that everyaccredited MP must comply with the applicable setof jurisdictional SIRs. Therefore, we recommendadding v) to the applicable Service Installation Rules(SIRs) or the Distributor's reasonable technicalrequirements within the jurisdiction.

2.2 Use of sub-contractors

Regarding 2.2(e) AusNet Services regards that theMP only needs to notify AEMO “if a change insub-contractor represents a significant proportion ofthe MPs workforce or capabilities”.

2.3 Insurance

3Device management and Testequipment

3.1 Purchasing

3.2Storage, handling andtransport

3.3Management of test In relation to 3.3(b) AusNet Services considers that



equipment seven years is an unreasonable period of time tohold records of test equipment including calibrationcertificates. The seven-year obligation should onlyextend to metering data. Equipment is tested everyone or two years. If MPs are audited every twoyears then the requirement should only extend twoyears. Therefore, we recommend changing to aperiod of two years.

3.4

Management of meterprogramming and authorisedsoftware

In relation to 3.4(b) AusNet Services considers thatmaintaining records of authorised software andprograms seven years is a very onerous requirementwith very little value. The respective metermanufacturers for the meter programming ofelectronic meters provide the proprietary software.Various re-iteration and combinations of meterfirmware and meter programs, as well as commsfirmware and platform versions. The seven-yearobligation should only extend to metering data.Section 6.1 only requires 13 months for maintaininga register of metering installations. If MPs areaudited every two years then the requirementshould only extend two years. Therefore, werecommend changing to a period of two years.

4Installation andcommissioning requirements

4.1General commissioningrequirements Regarding 4.1(a) AusNet Services considers the MP’s

processes and procedures should also extend to the



maintenance of the electrical wiring at the meteringinstallation, as well as the installation. Further, weinsist that all aspects of the metering installationmust meet AS3000 and relevant Service InstallationRules (SIRs) including neutral, impedance andpolarity tests, whilst the current proposed wordsonly refer to having cable sizes meeting therequirements of AS3000. Therefore, we recommendaltering to the following words.

i. wired, terminated and maintained in compliancewith meter and instrument transformermanufacturer requirements, AS3000 and otherrelevant Australian Standards and ServiceInstallation Rules (SIRs) or the Distributor'sreasonable technical requirements Jurisdictionaldocuments;

iv. connected with the correct polarity at eachtermination and tested to confirm the correctpolarity in accordance with jurisdictional standards;

Regarding 4.1(b) AusNet Services consider theobligations are in fact in relation to two differentobligations and should be listed separately as b) andc). The first is to have documentation from therelevant standards body to which the meterinstallation equipment complies with the NERobligations. The second obligation is to ensure thenameplate with information aligns with the NMIpattern approval process.



Regarding 4.1(h) AusNet Services considers thefollowing words “and may include a timing check…”to be confusing and superfluous only applying in asmall minority of metering installations whereby thesecondary energy recorded at the meter can beverified to ascertain the correct primary loadthrough the CT.

In relation to 4.1(i) AusNet Services understands thatcommissioning associated testing was agreed to onlyapply where CT metering is connected, so thisobligation to investigate alarms should only appliesto meters connected to CT metering. Secondly, weconsider the wording of "significant meter alarms"should be retained, and/or reference made toSection 7.2, which details this validation. Meteralarms can be a lot broader than just those alarmsrelated to meter Validation.

Regarding 4.1(k) AusNet Services recommendsadding a reference to the applicable national safetystandards, and in the situation of group meteringarrangements to not interfere with existing meter orcommunications equipment. As such werecommend the following words, ”… it is installed inaccordance with the manufacturer’s instructions,national safety standards, in a manner that does notinterfere with other meter communicationsequipment (in a group metering arrangement) andthat maintains the integrity of the meter enclosure,including water and environmental seals.”



4.2Metering Data ValidationRequirements

In relation to 4.2 AusNet Services considers thatcommissioning tests and on site Validation asoutlined 4.2(a)(iii) is only appropriate for CTmetering. It was agreed at an AEMO workshop toonly apply such obligations where CT metering isconnected and not to mass-market directly connectmeters. We recommend altering 4.2(a)(iii) to say“where metering installation is connected to a CTthe measured and stored interval energy data withinthe meter’s buffer is Validated with the intervalmetering data as remotely read and stored withinthe MDP’s metering data services database.”

Regarding 4.2(b) AusNet Services suggest that ratherapplying “one or more” conditions it is moreappropriate to say “iii And a combination of i, ii, andiv.”

4.3

Notifications followingMetering InstallationCommissioning

In relation to 4.3 Table 1 AusNet Services considersthe Load type description should also reflectdifferent load types connected to different meterelements, for example: E2 supplies the Hot Water.In addition, we consider that the Licence number isnot required where a qualified employee ofdistribution business in accordance withjurisdictional safety requirements replaces themeter.

4.4 Meter Churn Regarding 4.4(a)(i) and (ii) AusNet Services considersthe obligation to make “reasonable endeavours to



contact the Current MDP” should apply even if themetering installation does not include a CT. TheMDP applies the same Validation procedureirrespective of whether a CT is connected. Werecommend removing the words “and includeinstrument transformers” from 4.4(a) and adding to4.4(a)(iii) words “where the metering installation isconnected to a CT”.

In relation to 4.4(a)(iii) AusNet Services suggestsremoving the reference to “verify the Current MDPundertakes a final read” from 4.4(a)(iii)”, becauseverifying meter reads is not appropriate for amass-market meter churn.

Regarding 4.4(b) & (c) AusNet Services recommendthat communications to the Current MP and NewMDP also include the details in Table 1: Notice ofcompleted installation work.

AusNet Services consider that 4.4(g) would requireall network device meters be removed irrespectivewhether NER 7.8.6(f)(3) applies. Instead, werecommend adding the words “except where theredundant meter is used as a network device”.

In relation to 4.4(h) AusNet Services regard theFRMP, DNSP, and LR must be informed beforeproceeding with the exchange. We suggest addingthe following words to the end of 4.4(h) “after theMC has advised the FRMP, DNSP, and LR.”



5Metering installationmaintenance

5.1 Test Plan

In relation to the first paragraph in 5.1 AusNetServices considers the NER allocates obligationson the MC for the overall responsibility for the AssetManagement Strategies and the associated TestPlan. It is the MC’s responsibility to ensure themetering installation meets the inspection andtesting requirements of the S7.6.1 NER. The MPmust provide the necessary expertise as outlined inNER S7.2.3 and maintain records of tests andinspections. Therefore, we recommend removing5.1 (a), (b), and (c) and replace with “The MP mustprovide the necessary expertise as outlined in NERS7.2.3 and maintain records of tests andinspections.”

5.2Management of MeteringInstallation Malfunctions

5.3 Telecommunications

Regarding the first paragraph in 5.3 refers to theMDP and MC, but should only refer to the MDP. TheMDP would have the overall obligation to ensureservice providers are performing as per theirobligations

In relation to the second paragraph in 5.3 AusNetServices considers the words imply the MP must



assist in the manual collection of metering data,whilst this is the obligation of the MPC. We suggestremoving the paragraph.

5.4Non-Conforming Test Resultsor Calibrations Spelling error in 5.4(c) “notification"

6 Systems and administration

6.1 Metering Register

6.2Security Controls for Accessingthe Metering Installation

Regarding 6.2(b) AusNet Services consider morethan just remote access passwords are required toremotely access a metering installation, where IPsecurity requirements and risk based assessmentsprovide more comprehensive protections. Wesuggest removing 6.2(b).

6.3 Disaster Recovery

In relation to 6.3(c) AusNet Services consider a fullannual end-to-end fail-over test/recovery test isdisruptive to yearly service levels (eg AMI servicelevels) and onerous on the business. The end-to-endsystems will no doubt involve MDP and MC systemsand be out of scope from this document. Therefore,we recommend removing 6.3(c).

6.4 Audits undertaken by AEMO



6.5 Review of Accreditation

6.6 Quality Systems

6.8 Disputes

12. Other Issues Related to Consultation Subject Matter

Document Clause Heading Participant Comments

NEM ROLRPROCESSES – PartB – B2B Procedures

Part B (sections101 to 105)

AusNet Services observed that the entire Part B (sections 101 to 105) ismissing the necessary changes to conform to the new Procedure draftingand to align with Rule changes. These sections require updating even ifonly to update inconsistent terminology.