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4 August 2011

Dear Mr Sarcich

Discussion paper: Victoria specific regulatory requirements under the NECF

AEMO welcomes the opportunity to provide a response to DPI's Victoria specific regulatory requirements – discussion paper. AEMO supports DPI's approach to implementing the National Energy Customer Framework (NECF) and review of Victorian regulations. AEMO would like to make the following points regarding the discussion paper:

Victorian NMI standing data requirements

Section 3.3 of the discussion paper suggests retaining the jurisdictional requirements for standing data to facilitate efficient customer transfers in the market through AEMO. The National Electricity (Miscellaneous & Consequential) Amendment Rules 2010 clause 3.13.12A requires AEMO to develop a scheme for a national metering identifier (NMI) standing data schedule that will replace the current jurisdiction specific schedules (as a minimum AEMO currently specifies the same standing data items through MSATS Procedures). AEMO will be developing this schedule in consultation with jurisdictions and registered participants. Thus, AEMO believes that the jurisdictions do not need to retain existing jurisdictional NMI standing data requirements.

Benchmarks for unaccounted for gas

Section 3.5.3 of the discussion paper suggests that the benchmarks be retained in Victoria. AEMO supports retaining the benchmark rates for unaccounted for gas (UAFG) in Victoria. However, AEMO notes that while the paper indicates in section 3.5.3 that the Victorian energy regulatory rules (VERR) provision is outlined in section 4 table 5, there does not appear to be any reference in Section 4 relating to the management of the UAFG benchmarks. AEMO is also keen to understand the proposed approach to the setting of the benchmarks on a year to year basis.

AEMO will continue working with the DPI on the review of the Electricity System Code and technical requirements of the Electricity Distribution Code and Gas Distribution System Code.

If you require any further details, please do not hesitate to contact Paul LeFavi, A/Senior Manager, Electricity Retail Market Development on (03) 9609 8341 or by email at paul.lefavi@aemo.com.au.

Yours sincerely

Terry Grimwade

Executive General Manager, Market Performance