Australian Airports Association formally endorses and supports the than 30 tenants will not be affected except where a customer seeks a market offer. content of the Brisbane Airport Corporation submission and feedback from members indicates it aligns with the general views held by major Brisbane Airport Corporation submission airports nationwide. Energy Billing on-market EN customers Billing on-market EN customers Intelligence Generally support proposal that ENO primarily responsible regarding We will issue guidance notes where necessary to duplication of network charges for brownfield sites and authorised help resolve any implementation issues with the retailers being primarily responsible for greenfield sites. new requirements. Fees, charges and transaction costs Recommend amendment to wording of proposal so ENO must use ‘best endeavours’ to resolve any duplications for brownfield retrofits. There We have not amended condition 4.6.4.1 as are cases in brownfield sites where the ENO has done all possible to suggested to resolve the concern with minimise duplication of charges but retailers or distributors have not communication with legacy metering installations. updated their appropriate systems to resolve duplication. We do not consider it always necessary to replace the meter. Meters may only require the Fees, charges and transaction costs communication card be replaced or reprogrammed Recommend condition 4.6.4.1 regarding manual read charges for to work with a new service provider. We also do not advance technology meters be amended. Where a new owner inherits accept that meters in embedded networks should an EN and the incumbent meter provider chooses not to supply remote be subject to lesser requirements than all other access metering data for commercial reasons, the new ENO must advanced technology meters. manual read the meters or replace them all. This would place significant costs on the ENO for no additional immediate benefit to end users. Metering and access arrangements We do not agree that ENOs should be protected by Metering types and access arrangements a termination fee. This condition is intended to Recommend ENOs be afforded the same financial protections as encourage reuse of an existing compliant meter. distributors (in relation to stranded assets) and maintain the ability to No argument is presented that demonstrates why a apply a reasonable termination fee consistent with the principles of termination charge would better satisfy the NEO. Chapter 6 of the NER. We do not believe the guideline prevents an Recommend greater clarity be provided relating to meters installed embedded network operator from voluntarily before 1 January 2012. Where a single meter needs to be replaced at changing a meter. an older site, it would be cost prohibitive to maintain data
Australian Airports Association formally endorses and supports the content of the Brisbane Airport Corporation submission and feedback from members indicates it aligns with the general views held by major airports nationwide. than 30 tenants will not be affected except where a customer seeks a market offer. Brisbane Airport Corporation submission Energy Intelligence Billing on-market EN customers Generally support proposal that ENO primarily responsible regarding duplication of network charges for brownfield sites and authorised retailers being primarily responsible for greenfield sites. Recommend amendment to wording of proposal so ENO must use ‘best endeavours’ to resolve any duplications for brownfield retrofits. There are cases in brownfield sites where the ENO has done all possible to minimise duplication of charges but retailers or distributors have not updated their appropriate systems to resolve duplication. Fees, charges and transaction costs Recommend condition 4.6.4.1 regarding manual read charges for advance technology meters be amended. Where a new owner inherits an EN and the incumbent meter provider chooses not to supply remote access metering data for commercial reasons, the new ENO must manual read the meters or replace them all. This would place significant costs on the ENO for no additional immediate benefit to end users. Metering types and access arrangements Recommend ENOs be afforded the same financial protections as distributors (in relation to stranded assets) and maintain the ability to apply a reasonable termination fee consistent with the principles of Chapter 6 of the NER. Recommend greater clarity be provided relating to meters installed before 1 January 2012. Where a single meter needs to be replaced at an older site, it would be cost prohibitive to maintain data Billing on-market EN customers We will issue guidance notes where necessary to help resolve any implementation issues with the new requirements. Fees, charges and transaction costs We have not amended condition 4.6.4.1 as suggested to resolve the concern with communication with legacy metering installations. We do not consider it always necessary to replace the meter. Meters may only require the communication card be replaced or reprogrammed to work with a new service provider. We also do not accept that meters in embedded networks should be subject to lesser requirements than all other advanced technology meters. Metering and access arrangements We do not agree that ENOs should be protected by a termination fee. This condition is intended to encourage reuse of an existing compliant meter. No argument is presented that demonstrates why a termination charge would better satisfy the NEO. We do not believe the guideline prevents an embedded network operator from voluntarily changing a meter.
AER%20Reasons%20for%20Decision%20-%20Amended%20Network%20Exemption%20Guideline%20-%20Version%205%20-%201%20December%202016.docx