Meter Churn Guidelines Consultation - Ergon Comment
7 pages
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Meter Churn Guidelines Consultation - Ergon Comment

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7 pages
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Ergon Energy Corporation Limited Financially Responsible Market Participant: Meter Churn Guidelines NEMMCO 29 February 2008 First Stage Rules Consultation Meter Churn Guidelines 29 February 2008 This submission, which is available for publication, is made by: Ergon Energy Corporation Limited PO Box 15107 City East BRISBANE QLD 4002 Enquiries or further communication should be directed to: Tony Pfeiffer General Manager Regulatory Affairs Ergon Energy Corporation Limited Email: tony.pfeiffer@ergon.com.auPh: (07) 3228 7711 Mobile: 0417 734 664 Fax: (07) 3228 8255 Or Jenny Doyle Regulatory Affairs Manager – Tariff Strategy Ergon Energy Corporation Limited Email: jenny.doyle@ergon.com.auPh: (07) 4048 4186 Mobile: 0427 156 897 - 1 - Overview Ergon Energy Corporation Limited (Ergon Energy) welcomes the opportunity to provide comment to the National Electricity Market Management Company Limited (NEMMCO) in response to its Notice of First Stage Rules Consultation, “Financially Responsible Market Participant: Meter Churn Guidelines” (Draft Guidelines). Ergon Energy supports NEMMCO’s development of Meter Churn Guidelines in accordance with clause 7.3.4(j) of the National Electricity Rules, to provide guidance on issues associated with changes in metrology and service provision resulting from meter churn. Table 1 details Ergon Energy’s comments on the proposed content of the Draft Guidelines. ...

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Ergon Energy Corporation Limited Financially Responsible Market Participant: Meter Churn Guidelines NEMMCO 29 February 2008
First Stage Rules Consultation
Meter Churn Guidelines
29 February 2008 This submission, which is available for publication, is made by: Ergon Energy Corporation Limited PO Box 15107 City East BRISBANE QLD 4002 Enquiries or further communication should be directed to: Tony Pfeiffer General Manager Regulatory Affairs Ergon Energy Corporation Limited Email:tony.pfeiffer@ergon.com.au Ph: (07)3228 7711 Mobile: 0417734 664 Fax: (07)3228 8255 Or Jenny Doyle Regulatory Affairs Manager – Tariff Strategy Ergon Energy Corporation Limited Email:jenny.doyle@ergon.com.au Ph: (07)4048 4186 Mobile: 0427156 897
 1 
Overview Ergon Energy Corporation Limited (Ergon Energy) welcomes the opportunity to provide comment to the National Electricity Market Management Company Limited (NEMMCO) in response to its Notice of First Stage Rules Consultation,“Financially Responsible Market Participant: Meter Churn Guidelines”(Draft Guidelines). Ergon Energy supports NEMMCO’s development of Meter Churn Guidelines in accordance with clause 7.3.4(j) of the National Electricity Rules, to provide guidance on issues associated with changes in metrology and service provision resulting from meter churn. Table 1 details Ergon Energy’s comments on the proposed content of the Draft Guidelines. Ergon Energy would welcome the opportunity to discuss this submission or provide further detail regarding the concerns that it has raised should NEMMCO require.
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TABLE 1 Consultation review comments submitted by:
Clause
General
2.5
4
Issue / Comment
It isn’t clear in all scenarios whether ‘FRMP’ is intended to refer to the current FRMP for the connection point or the new FRMP.
The Guidelines appear to address the impacts of meter churn for registered meter sites and does not consider an initial meter churn, i.e. when a customer first moves from nonmarket to market.
This will particularly be an issue for jurisdictions such as Queensland where competition has yet to mature and accordingly, where there are still a high number of initial churns occurring as large customers move from nonmarket to market arrangements.
There are a number of additional scenarios, the timely consideration of which may assist with the management of meter churn issues.For example:
 Checkwith LR/LNSP if remote meter reading and load profile data is installed,
 3 
Ergon Energy Corporation Limited
Proposed text
Change terminology to ‘new FRMP’ or ‘current FRMP’, as the context requires.
Clarify the intended scope of the Guidelines and consider expanded application to address initial meter churn as appropriate.
Consider expanding scenarios addressed by the Guidelines.
Date: 29 February 2008
Rating (H/M/L)
L
M
L
NEMMCO Response
Clause
4.3.2 and 4.3.3
Issue / Comment
that could facilitate a post meter churn;
load profile (type 5 meter) may be A installed and the addition of a communications unit would allow the meter to remain in place until the transfer date;
 Atype 5 meter may be programmed and display quantities for ‘basic reads’ to meet tariffs for nonmarket arrangements.For large customers secondary tariffs may be removed at the time of meter churn, making it very difficult to finalise the account;
 Themetering equipment should be returned by the new MPB to the designated location, with details of the removed location NMI, final reads, etc;and
 Finalreadings and date/time of removal of meter equipment need to be communicated to designated persons and data from the new meter supplied to the LR/LNSP up to the transfer date for account finalisation.
Ergon Energy queries whether the new FRMP will have access to the required information regarding the existing relationships and roles for the connection point prior to transfer completion.
 4 
Proposed text
Clarify the point in time at which these activities should be ‘considered’ by the new FRMP.
Rating (H/M/L)
L
NEMMCO Response
Clause
4.4.6 and 4.4.8
4.4.7
Issue / Comment
The intended application of these clauses is unclear. Clause4.4.6 requests consideration of a metrology change post transfer and clause 4.4.8 requests consideration of a meter change prior to transfer.
Ergon Energy believes that:
 Themeaning of ‘same type and form’ requires clarification. Is this intended to refer to the read type of the meter, meter manufacturer, mounting arrangements, or configuration (i.e. number of data channels, interval length, etc)?
with the comment above on Consistent clause 2.5, this principle may not be appropriate for application in circumstances of initial meter churn.For example, substantial work may be required to convert multiple single phase meters to one polyphase meter, remove unwanted meters or tariffs, etc.
 5 
Proposed text
Clarify the intended interaction of clauses 4.4.6 and 4.4.8.
Clarify the meaning of ‘same type and form’.
Rating (H/M/L)
M
M
NEMMCO Response
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