Consultation
Previously Consulted On
Downstream Reconciliation Options Paper
Submissions received
Consultation on Exemption under the Gas (Downstream Reconciliation) Rules 2008
Vector is seeking an exemption from rule 41 in respect of situations where:
- metering data fails Vector’s initial validation process and further enquiry reveals there is no demand-side reason for the failure; and
- a correction to the metering data is required as part of Vector’s validation process in order to accurately reflect actual flow; and
- Vector is able to create corrected data (which may in some cases include estimated data) to submit to the allocation agent, by the required deadline, that is likely to be closer to actual injection quantities than an estimation performed by the allocation agent in accordance with the estimation process set out in the allocation agent’s functional specification document.
Submissions received
Consultation on GTA Designation to add Papakura
Consultation on rule 37 percentage of error determination under the Gas (Downstream Reconciliation) Rules 2008
Submissions received
Proposed guideline for application of gas billing factors
Submissions received
Consultation on Exemption under the Gas (Downstream Reconciliation) Rules 2008
The annual UFG (AUFG) factor for the Greater Hamilton gas gate for the 2010/11 gas year has been affected by an error in TOU consumption submissions by a retailer. Now that the error has been identified and quantified, the allocation agent is seeking an exemption to allow recalculation of that AUFG factor.
Submissions close on 22 December so that, if a decision to grant the exemption were to be made, the allocation agent would be in a position to use an amended AUFG factor in time for the December initial allocation.
Submissions received
Consultation on Exemption under the Gas (Downstream Reconciliation) Rules 2008
The recent assignment of E-Gas customer contracts from the liquidator to Nova Gas necessitated an urgent exemption from the reconciliation rules to facilitate a more accurate result for the November 2010 initial allocation. Once an urgent exemption has been granted, Gas Industry Co must consult on that exemption. Please note that, as this is only a short paper and the issues appear to be straightforward, submissions are due on Friday 17th December 2010.
Submissions received
Consultation on rule 37 percentage of error determination under the Gas (Downstream Reconciliation) Rules 2008
This consultation paper seeks submitters' views on the appropriate percentage of error for the accuracy of consumption information provided for initial allocation, to be determined by Gas Industry Co, for the consumption periods in the gas year commencing 1 October 2010.
Determinations on the percentage of error applicable for each gas year can be found here
Submissions received
Consultation on proposed variations to exemptions under the Gas (Downstream Reconciliation) Rules 2008
Submissions are invited on a proposal to vary nine existing exemptions, all of which expire on 30 September 2010. The exemptions relate to direct connect gas gates, global 1-month UFG methodology gas gates, oversized metered gas gates, unmetered gas gates and to injection information supplied by transmission system owners. The variations sought extend the exemptions until 30 September 2012, thereby maintaining the status quo position whilst the major policy review of the reconciliation rules is undertaken.
Submissions received
Guideline Notes for the Gas (Downstream Reconciliation) Rules 2008
Submissions are invited on an updated draft of the Guideline note for rules 65 to 75 and 80: the commissioning and carrying out of performance audits and event audits.
This guideline note is intended to assist allocation participants in understanding the processes that will be adopted by Gas Industry Co when commissioning audits in accordance with the Rules. In particular, the updated draft includes a procedure for approving auditors, as well as the timetables Gas Industry Co intends to follow for performance audits of allocation participants.
The deadline for submissions is Wednesday, 18 August 2010.
Submissions received
Consultation on exemption application DR10-02-S under the Gas (Downstream Reconciliation) Rules 2008
Gas Industry Co has received an application from Contact Energy (Contact) for exemption from aspects of the Gas (Downstream Reconciliation) Rules 2008 (‘Reconciliation Rules’) in respect of the Te Rapa Cogeneration gas gate (TRC02003).
Submissions received
Consultation on Proposed Variations to Exemptions under the Gas (Downstream Reconciliation) Rules 2008
Submissions were invited on two issues relating to exemptions from the Gas (Downstream Reconciliation) Rules 2008. First, an urgent direct connect gas gate exemption was granted for the Hunua 3 gas gate in February 2010 and consultation was required on whether the urgent exemption should be varied, replaced or revoked. Second, it was proposed that the unmetered gas gate exemption currently in effect be varied by removing the Waverley gas gate. A gas gate meter has now been installed at Waverley and injection information is available, making the exemption redundant for this gas gate.
Submissions received
Exemption Application DR09-13-S under the Gas (Downstream Reconciliation) Rules 2008
Submissions were invited on an exemption application in respect of the Gas (Downstream Reconciliation) Rules 2008. The application sought to exempt the newly commissioned Kupe gas gate from certain provisions of the Rules in a similar manner to the existing direct connect gas gate exemptions.
Submissions received
Consultation on Proposed Variation to an Exemption under the Gas (Downstream Reconciliation) Rules 2008
Proposal to adddress the unmetered Papakura No.3 and Waverley gas gates.
Consultation Paper: Revocation/variation of exemptions under the Gas (Downstream Reconciliation) Rules 2008
Submissions were invited in respect of Gas Industry Co’s proposal to revoke or vary certain existing exemptions, which are now redundant as a consequence of the minor amendments to the Gas (Downstream Reconciliation) Rules 2008 (in force from 2 October 2009).
Submissions received
Consultation on proposed accuracy determination under the Gas (Downstream Reconciliation) Rules 2008
Submissions were invited on a consultation paper relating to the accuracy percentage to be determined under rule 37 of the Gas (Downstream Reconciliation) Rules 2008.
Prior to the beginning of each gas year, Gas Industry Co must determine and publish a percentage of error for the accuracy of the consumption information for allocation groups 3 to 6 provided for initial allocation (when compared against consumption information provided for final allocation).
Submissions received
Exemption Application DR09-12-U under the Gas (Downstream Reconciliation) Rules 2008
Submissions were invited on an exemption application in respect of the Gas (Downstream Reconciliation) Rules 2008. The application sought to exempt Nova Gas’ bypass networks from the allocation and reconciliation processes set out in the Rules.
Submissions received
Exemption Applications DR09-09-S, DR09-10-T and DR09-11-S under the Gas (Downstream Reconciliation) Rules
Submissions were invited on a package of three exemption applications in respect of the Gas (Downstream Reconciliation) Rules 2008. The applications related to the requirements for transmissions system owners to provide gas gate injection information in accordance with rules 41 and 42.
Submissions received
Draft report on exemptions granted in respect of rules 41 and 42 of the Gas (Downstream Reconciliation) Rules 2008
In September and November 2008, exemptions were granted exempting transmission system owners from some of the requirements of rule 41 and 42 regarding the provision of gas gate injection information. The exemptions expired on 30 April 2009 and prior to that date Gas Industry Co was required to provide a report on what actions should be taken in respect to the period from 1 May 2009 onward.
Gas Industry Co issued a draft report and consulted with allocation participants on some of the issues and possible outcomes discussed in the draft report – which can be downloaded below.
Submissions received
Exemption Applications DR09-06-T, DR09-07-T and DR09-08-T under the Gas (Downstream Reconciliation) Rules
Author: Bas Walker, Tristan Meo and Phillip Beardmore (Strata Consulting)
Submissions are invited on a package of three exemption applications in respect of the Gas (Downstream Reconciliation) Rules 2008.
Submissions received
Application of Gas Governance Arangements to Private Networks
The existing rules for reconciliation and switching make no distinction between open-access and private networks.
Gas Industry Co commissioned a paper by Dr Geoff Bertram to discuss how gas governance arrangements should be applied to private networks. Submissions were sought on the paper in April 2009, prior to which a workshop was held on 31 March (click here to view the slide presentation). The paper and industry participants submissions in response are set out below.
Gas Industry Co has now also prepared an analysis of submissions that discusses the conclusions of Dr Bertram’s report and considers the responses of submitters. The analysis of submissions can be viewed at the link set out below.
Submissions received
Consultation Paper: Exemption Applications under the Gas (Downstream Reconciliation) Rules 2008
Author: Tristan Meo and Phillip Beardmore (Strata Consulting)
Submissions were invited on a package of five exemption applications in respect of the Gas (Downstream Reconciliation) Rules 2008.
Submissions received
Consultation Paper: Proposed Guideline Notes for the Gas (Downstream Reconciliation) Rules 2008
Author: Bas Walker, Tristan Meo, and Phillip Beardmore (Strata Consulting)
Submissions were invited on a package of six proposed guideline notes in respect of the Gas (Downstream Reconciliation) Rules 2008.
The proposed guideline notes were developed to assist allocation participants and the allocation agent in interpreting and applying the Rules and understanding Gas Industry Co’s expectations for related downstream allocation and reconciliation processes.
Submissions received
Consultation Paper: Proposed Transitional Exemption DR08-28-T under the Gas (Downstream Reconciliation) Rules 2008
Author: Bas Walker
Submissions were invited on a proposed transitional exemption application under the Gas (Downstream Reconciliation) Rules 2008. A consultation paper on this application can be viewed or downloaded here:
Submissions received
Consultation Paper: Three Exemption Applications under the Gas (Downstream Reconciliation) Rules 2008
Author: Bas Walker
Gas Industry Co received three additional exemptions under the Gas (Downstream Reconciliation) Rules 2008. This notice published and sought submissions on these exemption applications.
A consultation paper on these applications can be viewed or downloaded here:
Submissions received
Consultation Paper: Exemption Application DR08-24-U under the Gas (Downstream Reconciliation) Rules 2008
Author: Bas Walker
Gas Industry Co received an additional exemption application under the Gas (Downstream Reconciliation) Rules 2008 to apply the Global 1-Month UFG methodology to the Kiwitahi 2 gas gate KIW34202. This consultation paper published the exemption application, outlined some additional information and sought submissions in response.
Submissions received
Consultation Paper on Exemption Applications under the Gas (Downstream Reconciliation) Rules 2008
Author: Bas Walker
Introduction
Subsequent to the release of its initial exemptions consultation paper on 21 August 2008 (“Initial exemptions under the Gas (Downstream Reconciliation) Rules 2008”), Gas Industry Co received additional exemption applications under the Gas (Downstream Reconciliation) Rules 2008.
This notice published and sought submissions on those additional applications for consultation purposes. Submissions received helped to inform Gas Industry Co’s consideration of the exemptions sought and ensured that all relevant factors were taken into account.
Gas Industry Co notes that the applications generally relate to issues that have already been the subject of earlier consultation, albeit in respect of different gas gates or allocation participants. As such, a relatively compressed period of consultation was allowed.
Summary of applications and links to previous applications
The applications received are summarised in the table below. The table also sets out the connection with previous applications. Those previous applications can be located in the initial exemptions consultation paper of 21 August 2008. The following submissions were received:
|
Applicant and application Code |
Summary of exemption sought |
Connection with previous applications |
|
Nova Gas Ltd DR08-20-S |
Exemption from application of the allocation and reconciliation provisions of the Rules for five single retailer (bypass) gas gates/one direct consumer gas gate |
See previous applications on this issue from Genesis Energy DR08-06-S, Contact Energy DR08-06-S, On Gas DR08-10-S and Mighty River Power DR08-11-S |
|
Nova Gas Ltd DR08-21-S |
Exemption of five single retailer (bypass) gas gates/one direct consumer gas gate from the allocation of ongoing fees |
See previous applications on this issue from Genesis Energy DR08-07-U, Contact Energy DR08-08-U, On Gas DR08-09-U and Mighty River Power DR08-12-U. |
|
Powerco Ltd DR08-22-S |
Exemption of the unmetered Matapu and Pungarehu No. 2 gas gates from the requirement for accurate metering |
See the previous Gas Industry Co proposed exemption DR08014-T on this issue |
|
Bay of Plenty Energy DR08-23-T |
Exemption from applying seasonal daily shape values for a specified period of time. |
See previous application from Nova Gas DR08-03-T on this issue. |
Submissions received
Consultation Paper on the Initial Package of Exemption Applications under the Gas (Downstream Reconciliation) Rules 2008
Author: Bas Walker and Tristan Meo
The Gas (Downstream Reconciliation) Rules 2008 went into full operation (go-live) on 1 October 2008. These Rules provide for participants or the allocation agent to apply for exemptions from the rules, and these applications can be standard, urgent or transitional.
Exemption applications were invited in late July so that they could be processed before go-live. Including two transitional applications from Gas Industry Co itself, a total of 18 applications were received. It was decided to consult participants on all of these applications, so that we could be sure that the interests of all participants would be appropriately recognised and taken into account. Exemption applications also formed a very useful part of the information-sharing process leading up to go-live.
The consultation paper can be viewed or downloaded form here:
Submissions received
Consultation Paper: Proposed Determinations and Other Matters under the Gas (Downstream Reconciliation) Rules 2008 - Second submissions
The consultation paper on Proposed Determinations and Other Matters under the Gas (Downstream Reconciliation) Rules 2008 covered two groups of matters, and there was two different closing date for submissions. The submissions with the closing date of 11 July 2008 can be viewed or downloaded form here:
Submissions received
Consultation Paper: Proposed Determinations and Other Matters under the Gas (Downstream Reconciliation) Rules 2008
Author: Bas Walker and Lucy Elwood
A consultation paper on proposed determinations and other matters under the Gas (Downstream Reconciliation) Rules 2008 was released by Gas Industry Co on 13 June 2008. Submissions were sought from interested parties. The consultation paper covers two groups of matters, and there was a different closing date for submissions for the two groups, as follows:
- with a closing date of Friday 27 June 2008, proposed information exchange file formats
- with a closing date of Friday 11 July 2008, proposed information requirements from transmission system owners, proposed percentage of accuracy, proposed groupings of gas gates, additional information exchanges, provision of reports and information by the allocation agent to allocation participants, notifications to the allocation agent, and issues around gas measurement systems and the definition of gas gate.
Consultation was formally limited to prospective allocation participants, rather than more widely. However, the consultation paper has been published on the Gas Industry Co website for general information.
Submissions received
Discussion Paper - Reconciliation of Downstream Gas Quantities
Author: Lucy Elwood
This discussion paper builds on the feedback received from stakeholders on a previous reconciliation discussion paper released in June 2006. It focuses on downstream reconciliation and details Gas Industry Co’s preferred approach for addressing areas where current downstream reconciliation practices are failing to deliver Government’s policy aims or appropriately meet industry’s requirements. The preferred approach could potentially be implemented under either a pan-industry agreement or a regulatory arrangement. The analysis suggests that a regulatory arrangement is most appropriate, but Gas Industry Co intends to perform a cost-benefit analysis and consider further feedback from stakeholders before ruling out a pan-industry agreement. Attached to the discussion paper as Appendix D is a high-level summary of the possible structure of a regulatory arrangement and attached as Appendix E is a framework cost-benefit analysis paper prepared by NZIER.
Submissions received
Options Paper: Options for Amending Allocation and Reconciliation Arrangements
Author: Paul Mitchell
This consultation paper describes current allocation and reconciliation arrangements in the gas industry and reviews options for developing these.