Advanced Gas Metering

Infrastructure
Consultation Paper

7 August 2023
 Executive Summary

This paper sets out Gas Industry Co’s approach to potential requirements for a
regulatory framework and/or non-regulatory arrangements for a Statement of
Proposal (SOP) to support the deployment and use of Advanced Gas Metering
Infrastructure (AGMI) across domestic and commercial consumers’ gas
connections.

In 2017, Gas Industry Co undertook a review into gas metering focusing on metering service
provider arrangements and review of advanced metering technology.

In September 2021, Gas Industry Co published its Advanced Gas Metering – Issues Assessment 1
paper. The paper set out a preliminary list of potential issues on the deployment of advanced
metering technology into the gas market.

In December 2021, Gas Industry Co published Advanced Gas Metering Submissions Review and
Recommendations 2, the updated assessment of the priority to be afforded to each of the
identified issues, and recommendations on how each of these issues should be progressed.

Gas Industry Co also sets out in this paper the issues that it proposes to maintain a ‘watching
brief’ over – postponing any further work on these issues, pending market developments.

The paper recognises the discussions with stakeholders and submissions on previous papers
concerning identified AGMI issues.

In November 2022, Gas Industry Co established the AGMI working group, where stakeholders
provided further feedback and generally requested Gas Industry Co to focus only on the
following high priority issues:
Initial Section Description Priority
issue in this
paper
2 2 Minimum data standards and file formats Type A
3 1 Access to, ownership, use and security of Type A
customer data

17 1 Streamlined process for customer requests for Type A

consumption data (EPR C3)

18 1 Ensure distributors have access to smart meter Type A

data on reasonable terms (EPR E3)

4 3 Potential process and registry changes (including Type A

switching procedures)

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 Initial Section Description Priority
issue in this
paper
5 4 Downstream Reconciliation Rules Type A
20 4 D+1 Type A

Submissions
This consultation provides stakeholders with transparency on how Gas Industry Co intends to
address the specific AGMI issues.

All issues have been discussed in detail with the industry working group and many have no or
little relevance or benefit to significantly support the uptake of gas smart meter deployment
and competitive metering market.

Therefore, Gas Industry Co suggests that submitting parties focus on the priority “A” issues.
These submissions will help Gas Industry Co to prepare an SOP.

Written submissions on this Consultation Paper should be emailed to Gas Industry Co

[email protected] by 5pm on Monday, 4 September 2023. Please note that
submissions received after that time may not be able to be fully considered.

Submissions may be amended at any time prior to the closing date. All submissions will be
published automatically on Gas Industry Co’s website after the closing date. Submitters should
discuss any intended provision of confidential information with Gas Industry Co prior to
submitting the information.

Gas Industry Co is happy to meet with any stakeholder who wishes to discuss the position
paper in more detail.

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Contents

INTRODUCTION 7
Purpose 7
Background 7

1. ACCESS TO, USE AND SECURITY OF CONSUMER

DATA 12
1.1 Current state of access, use and security of consumer
data 12
1.1.1 What is “consumer data”? 12
1.1.2 Who may require access to meter data? 13
1.1.3 How is consumer data made available? 13
1.1.4 What safeguards are there regarding the security of
data? 14
1.2 Issues 14
1.3 Recommendation 15

2. MINIMUM DATA STANDARDS AND FILE

FORMATS 17
2.1 Issue 17
2.2 Recommendation 17
2.3 File Formats 18
2.3.1 Regulated file formats 18
2.3.2 Non-regulated file formats 18

3. GAS REGISTRY AND SWITCHING PROCESS

CHANGES 19
3.1 Issue 19
3.2 Recommendation 19
3.2.1 Meter Owner role 19
3.2.2 ICP parameters in the gas registry 20
3.2.3 Switching process & timeframes 20

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4. DOWNSTREAM RECONCILIATION AND D+1 22
4.1 Issue 22
4.2 Recommendation 22
4.2.1 Allocation group definition 22
4.2.2 Metering interrogation requirements 23
4.2.3 Submission of information to the allocation agent 23
4.2.4 Allocation methodology and UFG calculation 23
4.2.5 G1M determination 23
4.2.6 Residual profile and daily shape values 23
4.3 D+1 23

5. ALIGNMENT OF GMSAS 25
5.1 Issue 25
5.2 Recommendation 25

6. GMSA PAYMENT PROVISIONS 26

6.1 Issue 26
6.2 Recommendation 26

7. COST AND BENEFIT TO CONSUMERS 27

7.1 Issue 27
7.2 Recommendation 27

8. AGMI REDUNDANCY RISK 28

8.1 Issue 28
8.2 Recommendation 28

9. ADVANCED METER DISPLACEMENT 29

9.1 Issue 29
9.2 Recommendation 29

10. GMS OWNERSHIP AND STANDARD 30

10.1 Issue 30
10.2 Recommendation 30

11. ADVANCED METERING CONSUMER EDUCATION 32

11.1 Issue 32

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 11.2 Recommendation 32

12. MARKET COMPETITION 33

12.1 Issue 33
12.2 Recommendation 33

13. PREFERRED SUPPLIER PROVISIONS IN LEGACY

GSMAS 34
13.1 Issue 34
13.2 Recommendation 34

14. REMOTE DISCONNECTIONS AND

RECONNECTIONS 35
14.1 Issue 35
14.2 Recommendation 36

15. MULTIPLE TRADING RELATIONSHIPS 37

15.1 Issue 37
15.2 Recommendation 37

16. CRITICAL CONTINGENCY REGULATIONS 38

16.1 Issue 38
16.2 Recommendation 38

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 Introduction

Purpose
This consultation paper outlines recommendations for progressing solutions to an enduring set
of arrangements to enable the deployment and use of gas smart meters. It includes proposals
for amendments to the Rules and Regulations but also considers issues which could be solved
with a non-regulatory approach to meet the industry’s needs. It also highlights the low-priority
issues where Gas Industry Co intends to monitor the market development before taking
regulatory action or intends to take no further action.

Feedback will inform our forthcoming Statement of Proposal (SOP), which will contain a more
detailed assessment of the regulatory and non-regulatory recommendations (including a cost-
benefit analysis), as required by the Gas Act 1992, and will invite more substantive submissions
from stakeholders. Depending on feedback, the SOP will most likely only address priority “A”
issues.

Background
In 2017, Gas Industry Co undertook a review into gas metering focusing on metering service
provider arrangements and review of advanced metering technology.

Submissions highlighted that there was no settled view on the right technical solution, that the
market should be allowed to develop without regulatory intervention to ensure that innovation
was not hampered; and determining some minimum standards would be a pragmatic step to
ensure a common understanding of what market participants want from advanced metering.

Gas Industry Co published its Advanced Gas Metering – Issues Assessment 3 paper in September
2021 following initial informal discussions with several gas market stakeholders. The paper set
out a preliminary list of potential issues on the deployment of advanced metering technology
into the gas market, with our initial commentary on each of the issues, and an initial
assessment of the priority to be afforded to each issue.

Gas Industry Co considered submissions and on 17 December 2021, Gas Industry Co published
Advanced Gas Metering Submissions Review and Recommendations 4, the updated assessment of
the priority to be afforded to each of the identified issues, and recommendations on how each
of these issues should be progressed.

In November 2022, Gas Industry Co established the AGMI working group. The AGMI working
group is to provide advice on issues related to the deployment of advanced gas metering
infrastructure into the New Zealand retail gas market. The AGMI working group’s main
objective is to support Gas Industry Co to develop potential solutions to address identified
issues and to set priorities.

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Assessment.pdf
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Many of the issues initially listed in the Advanced Gas Metering Infrastructure Issues Assessment
paper reflected participants’ experience of the smart meter roll-out in the electricity sector. It
quickly became clear that the use-case for gas smart meters is very different and limited
compared to electricity smart metering, thus, requiring different solutions, reprioritising, and
combining issues.

A description of these issues and Gas Industry Co’s recommendations on how these issues
should be progressed, is set out in this paper.

However, all initially identified issues, regardless of the priority, are in this consultation paper to
provide interested parties a comprehensive picture of the gas smart metering situation.

Gas Industry Co classified the different AGMI issues by using the following categorisation:

Priority Groups Issue Key

Issues that likely require priority Gas Industry Co consideration. Note, priority may be Type A
given to an issue either due to its potential materiality to the outcomes and objectives
that Gas Industry Co is expected to pursue under the Government Policy Statement on
Gas Governance 5 and the Gas Act and/or due to timing considerations – that is, the
nascent state of advanced gas metering in New Zealand enables some shaping of
market outcomes now, with change becoming more difficult or costly to achieve over
time, as market penetration of AGMI increases.
Issues that likely allow a ‘watching brief’ and/or lower priority Gas Industry Co Type B
consideration either due to timing considerations or materiality to the outcomes and
objectives which Gas Industry Co is expected to pursue under the GPS and the Gas
Act.
Issues that Gas Industry Co does not consider to be relevant to delivering on the Type C
outcomes and objectives which Gas Industry Co is expected to pursue under the GPS
and the Gas Act.

The colour coding allocates issues to specific classification groups.

Other Technology/ Data usage, Downstream GMSA related Costs and
systems/ access, and Reconciliation issues benefits to
information terms and allocation of customer
exchange UFG

The collaborative prioritisation process resulted in the below list of priorities and streamlined
combination of issues. Due to the combination of relevant issues in this consultation, we could
not maintain the initial issue numbering. To make it easier for parties to cross reference with
pervious papers, we have included the initial issue linked to the relevant section in this
consultation paper.
Initial Section Description Initial or Priority Combined Reason for revised
issue in this revised suggested with… priority
paper priority by GIC and
following the AGMI
initial working
submissions group
1 7 Costs and benefits to Type B Issue 8 Consumer outcomes are
consumers important but addressed
through the competitive
gas metering market and
ongoing monitoring of
potential consumer issues.

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Initial Section Description Initial or Priority Combined Reason for revised
issue in this revised suggested with… priority
paper priority by GIC and
following the AGMI
initial working
submissions group
2 2 Minimum data standards and Type A Issues 11, 12
file formats
3 1 Access to, ownership, use and Type A Issues 9,
security of customer data 17,18

4 3 Potential process and registry Type A

changes (including switching
procedures)
5 4 Downstream Reconciliation Type A Issue 20
Rules
6 5 Alignment of GMSAs Type A Type B Issue 16 At this point in time, GIC
doesn't see that there are
efficiency gains through
common GMSA terms. This
issue can be revisited if
issues arise.
7 6 GMSA payment provisions Type A Type B The allocation of costs
between retailers and
meter owners is a matter
for those parties.
If issues flow down to
consumer contracts this
could be considered as
part of GIC's role in relation
to contractual
arrangements with small
gas consumers.
8 8 AGMI redundancy risk Type A Type B Issue 1 Reprioritised due to
suggested combination
with issue 1.
Government policy settings
in relation to residential
connections are unclear at
this point.
The allocation of costs
between retailers and
meter owners is a matter
for those parties.
9 1 Centralised data provider Type A Type B Issue 3 The key issue is the data
access framework and
data sharing. Given the
small scale of the market a
more pragmatic approach
might be more economic.

10 9 Advanced meter displacement Type B Not an issue at this stage

11 2 Open access AGMI systems Type A Type B Issue 2 At this point, there is no
indication that access to
third party AGMI systems is
a barrier to the uptake of
AGMs.

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Initial Section Description Initial or Priority Combined Reason for revised
issue in this revised suggested with… priority
paper priority by GIC and
following the AGMI
initial working
submissions group
12 2 Technology standards Type A Type B Issue 2 GIC acknowledges
submitters' concerns that
there is a balance between
standardisation that
enhances efficiency and
competition and creating
inefficiency by mandating
a particular technology.
GIC notes that work in
relation to other issues will
promote an element of
standardisation in relation
to industry processes.
13 10 GMS ownership and works Type B Type C Gas Industry Co does not
see itself as having a role in
determining ownership of
AGMs or components of
metering infrastructure.
14 11 Advanced metering consumer Type A Type C This is not a priority “A”
education issue for the AGMI work
programme. GIC spoke to
GasNZ to take the lead in
this area.
15 12 Market competition Type B Type C Gas Industry Co does not
consider that it, or the
workgroup, can resolve
concerns around market
concentration referred to
under this issue (particularly
stakeholder comments
around price and quality
regulation under Part 4 of
the Commerce Act).
16 13 Preferred Supplier Provisions in Type A Type B Issue 6 Aligned with Issue 6 priority
legacy GMSAs
17 1 Streamlined process for Type A Issue 3 Aligned with Issue 3 priority
customer requests for
consumption data (EPR C3)
18 1 Ensure distributors have access Type A Issue 3 Aligned with Issue 3 priority
to smart meter data on
reasonable terms (EPR E3)
19 14 Remote disconnections and Type A Type C Participants are currently
reconnections not prepared to take the
inherent H&S risk of a
remote reconnection. Gas
Industry Co considers that
it doesn’t have a role in the
H&S aspect but would
consider supporting the
development of remote
disconnection/reconnectio
n guidelines.
20 4 D+1 Type A Issue 5 Aligned with Issue 5 priority
21 15 Multiple trading relationships Type C
22 16 Critical Contingency Type C
Regulations.

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The development of potential solutions for each of these issues must align the advanced gas
metering-related outcomes and objectives which Gas Industry Co is expected to pursue under
the GPS. Therefore, Gas Industry Co will focus on priority “A” issues only.
Initial Section Description Priority
issue in this
paper
2 2 Minimum data standards and file formats Type A
3 1 Access to, ownership, use and security of Type A
customer data
17 1 Streamlined process for customer requests for Type A
consumption data (EPR C3)

18 1 Ensure distributors have access to smart meter Type A

data on reasonable terms (EPR E3)

4 3 Potential process and registry changes (including Type A

switching procedures)
5 4 Downstream Reconciliation Rules Type A
20 4 D+1 Type A

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 1. Access to, use and security of
consumer data

Gas meters measure the volume of gas consumed at a gas connection and are
used for allocation of gas volumes to gas retailers and gas customer billing. The
replacement of legacy gas meters with advanced gas meters will change the
nature of consumer data that industry participants collect for an individual
consumer.

Domestic legacy meters record consumption on a continuous basis and this data is obtained
by a physical meter read. In many cases, there are several months between meter reads. In
contrast, some advanced gas meters record half-hourly data regarding a customer’s gas usage
and such data can be obtained by, and delivered to, a retailer remotely.
Concerns around the access to, use and security of customer data are heightened with the
introduction of advanced gas meters given the ability of these meters to collect more granular
information regarding a customer’s gas usage.
The ability of a smart meter to provide accurate consumption data in a timely manner also
requires consideration of who may require access to this data and for what purposes.
We have previously considered these issues under four separate headings:
1. Access to, use and security of consumer data
2. Streamlined process for customer requests for consumption data
3. Ensure that distributors have access to smart meter data on reasonable terms
4. Centralised data provider
We have combined the above issues in this section given that they have a common theme of
access to advanced meter data. The concept of a “centralised data provider” is more
appropriately characterised as a possible solution to concerns around data access, rather than
an issue that needed to be considered. However, we provide assessment of this as a possible
solution.

1.1 Current state of access, use and security of consumer data

1.1.1 What is “consumer data”?

For this paper, we consider “consumer data” to mean meter data or information used by a
retailer to determine the volume of gas consumed at each of the ICPs where a retailer supplies
gas to a consumer.
Consumer data is collected by retailers’ gas metering service providers and provided to gas
retailers for the purpose of their energy billing processes. These services are provided under gas
metering service agreements (GMSAs) that define the service provided by metering service
providers.

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The collection of consumer data is not limited to consumers who have an advanced gas meter.
Retailers also collect consumer data in relation to consumers who are supplied by a legacy
meter. However, given the infrequency of meter reads, consumer data from legacy meters is a
less valuable source of information regarding a consumer’s consumption behaviour.

1.1.2 Who may require access to meter data?

Consumer access
Consumers may seek to access information that industry participants hold regarding their gas
use for the purpose of undertaking price comparison or investigating energy efficiency
measures. Consumers have a right to access personal information that retailers hold about
their gas use in accordance with the Privacy Act 2020. In some cases, retailers have provided
consumers with access to consumption data through online applications, although the level of
granularity of this data may be less than the information that the retailer collects.
Consumer rights under the Privacy Act will not extend to consumer data that is not personal
information.
Third party access
Third parties (for example, energy brokers) may wish to access consumer data to provide
consumers with advice on alternative pricing options or energy efficiency measures. These third
parties are unlikely to have an agreement with retailers that entitles them to access an
individual consumer’s consumption data and will need to negotiate access to this data on a
case-by-case basis. Retailers will need to be satisfied that the consumer has consented to the
third-party having access to this data and comply with the requirements of the Privacy Act.
Distributor access
Gas distributors may also seek access to data associated with a consumer’s gas use for pricing
and network planning and management purposes. It is unclear whether distributors require
access to individual consumer data, or whether aggregated data is sufficient.
Gas distributors may require retailers to provide access to consumer data through their use-of-
system agreements. If distributors require such access, the retailer will be responsible for
obtaining any authorisations required under the Privacy Act for making the consumption
available to the distributor for the specific purposes. This is likely to require a “back-to-back”
arrangement in gas retail contracts between the retailer and the consumer whereby consumers
agree to the scope of distributor access to consumption data. Both distributors and retailers
will be incentivised to ensure that they comply with the requirements of the Privacy Act when
negotiating distributor access to meter data.

1.1.3 How is consumer data made available?

There is currently no standard process for consumers, third parties or network owners to access
gas consumer data, nor is there any standard form in which this information is made available.
Therefore, gas consumer data is made available in accordance with any arrangements that
are agreed between the retailer and the requesting party.
We are aware that MBIE is currently consulting on the establishment of a consumer data right
in New Zealand. The Consumer and Product Data Bill contemplates a data access regime
where certain “accredited requestors” have access to customer data through a direct, secure,
and standardised data transfer. Initially this will only apply to the banking sector, but the
consultation on the draft bill suggests that a data access regime could be applied to the

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energy industry. Detailed aspects of the framework will be specified in regulations and
standards that have not been developed yet.

1.1.4 What safeguards are there regarding the security of data?

The Privacy Act places obligations on those who collect personal information, such as
consumer data. These obligations include:
1. Protection against loss, unauthorised access, or misuse by reasonable security
safeguards.
2. If it is necessary that information is disclosed to service providers, all reasonable steps
are taken to prevent unauthorised use or disclosure.
3. Limiting the retention of information for no longer than the purpose for which the
information may be required for.
The requirements of the Privacy Act will apply to any gas industry participant who receives
personal information.

1.2 Issues
Consumer data that is not personal information
The Privacy Act only applies to personal information. For example, consumer data that relates
to a trust or company may not have the benefit of the protections in the Privacy Act. There
should be consistent access to customer data regardless of whether the data is personal
information and the customer can rely on the rights and obligations in the Privacy Act.
Third party consent for access to consumer data
Third parties (other than gas distributors) cannot require industry participants to provide them
with direct access to consumer data. Some industry participants may be willing to provide third
party access to consumer data with appropriate evidence of consumer consent, while others
may require the data to be supplied to the consumer who will be responsible for passing on the
data to the third party.
A consumer should be able to consent to a third-party having access to consumer data
directly from the relevant industry participant. There are efficiency benefits in standardising the
process to avoid the situation where consumers and third parties seeking access to consumer
data have to follow different approval processes for each industry participant.
In the electricity industry, the process for third party access to consumer data is regulated
through the Electricity Industry Participation Code (the Code). A standard form for consent is
prescribed.
We don’t believe that distributor access to consumer data should be considered under this
issue for the following reasons:
1. Gas distributors have an ongoing contractual relationship with retailers through their
use-of-system agreements. Combined with an overlay of the parties’ obligations under
the Privacy Act and experience with negotiation of electricity use-of-system
agreements, it should be possible to reach an agreed position on the terms of access to
consumer data. The agreed position is likely to be different to third party access.
2. The number of gas distributors and gas retailers is small in comparison to the number
of consumers and third parties who may wish to access consumer data. There are also

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 far fewer gas distributors and gas retailers than electricity distributors and electricity
retailers. The efficiencies associated with a standardised approach are lower.
3. Gas Industry Co has oversight of the terms of use-of-system agreements through other
workstreams.
The length of time that consumer data is retained
The Privacy Act requires that industry participants keep consumer data that is personal
information for no longer than is necessary for the purpose for which information may be used.
A retailer may determine that it is no longer appropriate that it keep historical consumption
information for a consumer, particularly if a consumer is no longer a customer, or has switched
to another retailer.
Historical consumption data can be valuable for consumers and third parties to develop a
profile of a consumer’s gas usage and make informed decisions about gas supply options. This
is particularly the case for price comparison purposes where comparison will often require a
year or more of consumption data.
In the electricity industry, the Code requires retailers to retain consumer data for a period that
is 24 months prior to the request.
Timeliness of the provision of consumer data
Currently there are no requirements or expectations around the timeliness of responses to
requests for consumer data other than the requirements of the Privacy Act.
The Privacy Act provides for consumers to be able to access consumer data that is personal
information and provides that a request must be complied with as soon as reasonably
practicable and generally no later than 20 working days.
In most cases, it should be possible for consumer data to be made available sooner than 20
working days.
In the electricity industry, the Code requires consumption information to be provided no later
than five business days after the date on which the request is made.
Standard format for provision of consumer data
There is currently no standard format for making consumer data available. As a request for
access to consumption data is likely to apply to an extended period (possibly months or years),
a consistent and usable data format will enable the efficient use of this information.

We note that the electricity industry has developed standard templates and electricity
information exchange protocols (EIEPs) to provide a standardised means for exchanging
consumption data.

1.3 Recommendation
Our recommendation is that Gas Industry Co facilitates the development of gas industry
specific guidance that addresses the identified issues as well as related issues that may be
identified during the development of the guidelines.
In our view, development of guidance is an appropriate response initially as:
1. Existing legal rights and obligations, such as the Privacy Act, already contribute to
defining appropriate access to, use and security of consumer data. There is no need to
duplicate these rights and obligations. Additionally, most of the identified issues relate

15
 to operational or process matters regarding consumer data rather than matters of
general principle.
2. The regulatory environment is likely to be impacted by the Consumer and Product
Data Bill and therefore a non-regulatory approach is better able to respond to
regulatory change.
3. Most gas industry participants are electricity industry participants and will already have
experience regarding access, use and security of consumer data. We do not anticipate
significant compliance issues.
In our view, the AGMI working group that we have established to consider issues around the
roll-out of advanced gas meters is an appropriate forum for development of the guidelines
followed by wider stakeholder consultation on draft guidelines.
In developing our recommendation, we considered the option of a centralised data provider as
had been referenced by some stakeholders during informal discussions prior to issuing our
Issues Assessment paper. This would align with the UK approach to access to advanced meter
data, whereby a central data communications company collects and manages advanced
meter data and provides data services to authorised parties such as retailers and network
owners. While that type of solution may address some of the issues that we have highlighted,
we believe that it would be both expensive and challenging to implement as an industry
arrangement for the New Zealand gas industry. We note that the UK model relies on a
regulated entity and rules relating to industry participant interactions with the regulated entity.
We do not consider that this type of solution should be considered further at this point of time
given the costs associated with a centralised data provider compared to any benefits
associated with an incremental improvement in access gas advanced meter data and the
small size of the New Zealand gas industry. It is also unclear how this type of solution would
interact with the framework in the Consumer and Product Data Bill if that framework is
extended to the energy sector.

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 2. Minimum data standards and file
formats

The AGMI working group broadly supported the development of a set of

minimum standards for AGMI and the adoption of a standardised approach for
recording and exchanging information. The market efficiency benefits of a
consistent approach can be inferred from the experience in the electricity
industry where there are multiple AMI providers and technologies.

2.1 Issue
The 2017 Gas Metering Review found that “A baseline of common terms and standards should
help to ensure that all retailers’ systems work with all meter owners’ systems. A couple of
submissions suggested that the gas industry should learn from the experience of the electricity
advanced metering roll out, where a lack of minimum standards resulted in misalignment
between metering data and retailer requirements in some cases and in poor outcomes for
some customers.”
In September 2017, Gas Industry Co issued an initial draft of a set of minimum metering
standards for discussion 6. At the time it was acknowledged that until a rollout began the
development of an AGMI standard would be slow.
The issue was flagged in the 2020 Issues Paper and submitters again supported Gas Industry
Co developing an AGMI guideline covering minimum standards. Our recommendation, for a
non-regulatory guideline approach, was preferred due to:
• consistency with the approach taken in electricity; and
• more flexibility than a regulatory arrangement, which is particularly important in
relation to a developing technology/emerging market.

2.2 Recommendation
We continue to believe that guidance on AGMI minimum standards would be beneficial and
that the non-regulatory approach is the correct course of action at this stage. We will work
with the AGMI working group to agree on the form and content.
Consistent with submissions on the Issues Paper and discussion with the AGMI working group,
we consider that the AGMI guideline should not be prescriptive regarding metering solutions or
technology, as we do not want to create a barrier to innovation.
Similarly, while there are perceived benefits to requiring open access AGMI systems, we
consider that given the small size of the gas industry, and the relative ease of modern
technology platforms to provide interoperability, it is not necessary to mandate this
requirement.

6
https://www.gasindustry.co.nz/assets/WorkProgrammeDocuments/5717201709-draft-minimum-metering-standards-ID-
22269.pdf

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In addition, we do not expect the AGMI guideline to be as broad in scope as the equivalent
guidelines in electricity. 7 The functionality of an electricity smart meter, coupled with the
dynamics of the wholesale electricity market, means that there is a demand for various types
of information from electricity meters (for example, load control, energy import/export) that
either does not exist in gas, is not measured by the meter, or has little market value.

2.3 File Formats

2.3.1 Regulated file formats

File formats for regulated processes, such as submitting consumption information to the
allocation agent, or updating registry ICP parameters, are determined, in accordance with
each set of rules, by Gas Industry Co in consultation with industry. Any amendments to these
file formats to provide for AGMI will use the existing change processes set out in the associated
rules.
Specific changes are discussed later in this paper in the individual sections for downstream
reconciliation and the gas registry and we expect to use the AGMI working group to assist with
drafting appropriate new or amended file formats before consulting more broadly.

2.3.2 Non-regulated file formats

Gas Industry Co facilitates the publication of several non-regulated file formats (gas
information exchange protocols or GIEPs) which are used for industry information exchange.
Alongside the development of the AGMI guideline, we will discuss with the working group
whether there is appetite for new non-regulatory, industry-wide file formats.

7
https://www.ea.govt.nz/documents/217/Guidelines_on_advanced_metering_infrastructure.pdf

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 3. Gas registry and switching process
changes

The gas registry is the database of record for ICP-related information, including
network, retailer, and metering parameters. The rollout of advanced gas meters
will impact existing fields in the registry and there may be appetite to capture
new information if it has value to registry participants. The registry also facilitates
customer switching and we should consider whether the advanced metering
rollout could improve the current switching process.

3.1 Issue
Potential changes to the gas registry and switching arrangements for advanced metering were
canvassed in 2017 but it was deemed too early at the time to determine which changes would
have a future benefit. The 2021 issues paper (and submissions thereon) suggested a number of
possible additional fields that could be populated relating to the meter, what it records, and
how it is used.
The AGMI working group discussed registry changes in detail and noted that there should be
clear benefits to making any amendments due to the wide industry system impacts and
associated costs. The discussions focussed on a few key areas:
• Roles and responsibilities relating to metering
• ICP parameters in the gas registry
• Switching process and timeframes

3.2 Recommendation

3.2.1 Meter Owner role

The AGMI working group considered whether roles and responsibilities for metering in the gas
registry and the Switching Rules may need to be updated with the introduction of advanced
metering. We observed that the gas registry already provides for a multiplicity of GMS owners
but only a single party (the responsible meter owner) has obligations under the Rules to
maintain ICP parameters. We discussed whether there is a likelihood that the owner of the
‘advanced’ components of the GMS may be different to the meter owner and, if so, whether
there would be a benefit in that party populating information that is distinct to the information
populated by the meter owner.
According to recent registry data, there are close to 50,000 advanced meters now installed. Of
these ICPs, fewer than 10 have an advanced meter owner that is different to the responsible
meter owner. This indicates that the parties installing advanced meters are the parties that
already have the responsibility for those ICPs in the registry.
At this stage, having discussed with industry participants at the issues paper stage and in the
working group, we do not consider that there is a strong possibility that a third-party
advanced meter owner, distinct from the existing meter owner, would need to populate

19
information in the gas registry. We therefore do not propose any changes to the meter owner
roles and responsibilities. If we determine that advanced meter information should be
populated and maintained in the registry, then the responsible meter owner will continue to
have that obligation.

3.2.2 ICP parameters in the gas registry

The AGMI working group agreed that the gas registry should separately identify:
• the capability of the GMS installed at a consumer installation; and

• the method that the responsible retailer is using to reconcile each ICP

We considered adding further meter/register content information to the gas registry in the last
set of amendments in 2014, but at the time this would have only benefitted TOU meters (about
500 ICPs out of a population of 300,000). With the much larger rollout of advanced gas
meters, the benefits to expanding the information held in the registry will be more widespread.
We believe that a single extra ICP parameter, maintained by the responsible meter owner,
would be sufficient to capture the required information on the capability of the GMS. Like other
registry fields, the values would be determined by Gas Industry Co in consultation with industry
and could be amended from time-to-time, which would allow for flexibility and future proofing.
The field could also be used to populate information about TOU ICPs that is currently
conveyed in the GTN, for example, whether metered gas volumes are pressure and
temperature corrected.

We think that a new allocation group should be created for AGMI ICPs (or one of the unused
allocation groups should be repurposed) to recognise that these ICPs are distinct from both
legacy interval-read mass market consumers and from large TOU consumers.

We also propose creating new values for the profile codes, by way of a Gas Industry Co
determination, to capture the submission of aggregated daily data that has been sourced from
AGMI. The only profile codes currently used are XTOU and GGRP, for TOU and mass market
customers respectively. The Rules also allow for dynamic deemed profiles for allocation group
5 consumers and static deemed profiles for allocation group 3 consumers, but these have never
been used.

We consider that the combination of allocation group and profile code (both existing registry
fields maintained by the responsible retailer) is sufficient to identify how the retailer is reporting
consumption. Therefore, no new retailer registry parameters are proposed.

3.2.3 Switching process & timeframes

The current gas switching process involves two or three steps:

• the requesting retailer sends a GNT notice to the responsible retailer, including certain
details such as the type of switch and, optionally, a requested switch date;

• the responsible retailer can then respond with an acknowledgement notice (GAN),
which communicates a response code and an expected switch date, which can be
aligned with the consumer’s monthly billing cycle;

• the responsible retailer completes the switch by sending a GTN notice on or close to
the switch date, which includes a switch read (that may be estimated) and details of
the meter setup.

20
The rollout of advanced gas meters could allow some streamlining of this process, for example,
switch reads could be communicated within 24 hours, removing the need for estimation, and
could be provided by the meter service provider rather than the responsible retailer.

The main benefits of these changes would be more timely switching and more accurate switch
reads. However, we believe that switching timeframes are already at an excellent level (as
illustrated below) and the number of switch read renegotiation requests suggest that there isn’t
any significant concern with the accuracy of switch reads 8. Hence, we do not propose any
changes to the switching process or timeframes as the marginal benefits would be unlikely to
exceed the cost of implementation.

Figure 1: Average Switching Length

8
Switch read re-negotiation requests peaked during the COVID lockdown period at 6.5% of completed switches but have
since fallen to 4.3% of completed switches and continue to trend downwards. Acceptances of switch read re-negotiation
requests currently sit around 3,4% of completed switches

21
 4. Downstream Reconciliation and
D+1

The Reconciliation Rules and associated systems and processes (including D+1)
need to be amended to provide for advanced gas metering. By including AGMI
data in the allocation processes this should improve the accuracy of retailer
allocations and reduce UFG. This will better support the purpose of those Rules,
which is to enable the fair, efficient, and reliable allocation, and reconciliation of
downstream gas quantities.

4.1 Issue
As with the Switching Rules amendments considered above, the issue here is the impact of the
rollout of advanced gas meters on an existing set of governance arrangements, the Gas
(Downstream Reconciliation) Rules 2008.
Gas Industry Co is obliged to ensure that all our governance arrangements remain fit-for-
purpose as gas market systems and technologies advance. In this context, we do not consider
that an assessment of non-regulatory alternatives is feasible for the below proposals.

4.2 Recommendation
Following discussion with the AGMI working group, we consider that incorporating AGMI into
the Reconciliation Rules will, at a minimum, impact on the following areas, which are discussed
in more detail below.
• allocation group definition
• metering interrogation requirements
• submission of information to the allocation agent
• allocation methodology and UFG calculation
• determination of G1M gas gates
• residual profile and daily shape values

4.2.1 Allocation group definition

As mentioned in the section on registry changes, we propose to define a new allocation group
for retailers with AGMI customers, to make these ICPs distinct from TOU ICPs (large C&I
customers in AG1&2) and legacy mass market ICPs (customers in AG4&6). Our intention would
be that retailers use this allocation group only for those ICPs where they:
• can reliably record and download daily metered energy quantities and
• intend to submit daily metered energy quantities to the allocation agent.
We believe that placing AGMI ICPs in a separate allocation group is the easiest way to clarify
the particular obligations that will apply to retailers with AGMI customers, for example,
metering reading requirements, submission requirements, and how UFG is applied.

22
4.2.2 Metering interrogation requirements

We intend to modify the existing meter reading requirements to include appropriate criteria for
how and when consumption information is recorded for the ICPs assigned to the AGMI
allocation group. If an ICP is assigned to this allocation group, then the retailer should be able
to demonstrate that consumption volumes for that ICP are being reliably downloaded and
submitted to the allocation agent.

4.2.3 Submission of information to the allocation agent

We will propose, in consultation with participants, a file format specification to submit AGMI
consumption data to the allocation agent. This will likely be similar to the existing GAS060
format, which is used for submitting aggregated daily volumes for multiple ICPs, rather than
the more granular GAS050 format, which is used for daily volumes for individual ICPs.

4.2.4 Allocation methodology and UFG calculation

The AGMI working group agreed that submissions of daily-metered volumes for AGMI ICPs
should be treated equally with TOU ICP volumes for UFG allocation. That is, they should have
the annual UFG factor applied rather than the monthly UFG factor. We will therefore propose
appropriate amendments to the global allocation methodology and calculation of UFG factors
to achieve this.

4.2.5 G1M determination

As the advanced gas meter rollout continues and market penetration increases, it will become
likely that the residual mass market volumes (i.e., non-daily metered volumes) at some
networks will be a small minority of the overall throughput. If the annual UFG factor is applied
to the majority of gas consumption at a gate this can cause unfair and unpredictable UFG
allocations to the residual mass market.
If and when this situation arises, we consider it appropriate to apply the G1M allocation
methodology, as is used currently when TOU volumes dominate network throughput. The
existing process to calculate and determine G1M gas gates would be amended to include
AGMI volumes as well as TOU volumes. Where those volumes exceed a certain threshold
(currently 80%), the G1M allocation methodology will be used at that gas gate, meaning a
monthly UFG factor will be applied to all consumption volumes.

4.2.6 Residual profile and daily shape values

Another consequence of increased AGMI penetration at a gas gate will be that the gas gate
residual profile (the difference between injection volumes and TOU+AGMI allocations) will trend
downwards over time. This will create an issue if the residual profile continues to be the basis
for the published seasonal adjustment daily shape values (SADSV), used by retailers to profile
read-to-read volumes of mass market customers. To ensure that it remains fit-for-purpose, we
propose amending the SADSV calculation to include AGMI volumes in the daily shape values.
We believe this should preserve the correct seasonal shape for profiling mass market reads.

4.3 D+1
A further set of proposals relate to the D+1 system and D+1 allocation service provided by the
Allocation Agent. Though D+1 is currently in a pilot phase, underpinned by a set of industry
agreements, Gas Industry Co intends to transition D+1 into the Reconciliation Rules imminently.

23
D+1 uses the best information available the day after gas has flowed to estimate each retailer’s
gas deliveries. Currently the D+1 system receives daily data for gas gate injections and for AG1
ICPs. Volumes for AG2 ICPs and the mass market are estimated using regression models.
We consider that AGMI data should be submitted to the D+1 system each day to increase the
accuracy of D+1 allocations. As well as increasing the ‘known’ data for the previous day, we
believe there will be further benefits:
• the residual mass market allocated volumes will be smaller (and therefore the
estimation errors will be smaller) and
• the accuracy of the mass market regression models could potentially be improved as
the aggregated AGMI data will provide a timelier demand dataset to supplement the
initial, interim, and final allocation data that is currently used to train the models.
When we issue a Statement of Proposal to put D+1 into the Reconciliation Rules, we will include
amendments to the D+1 allocation process to incorporate AGMI data. The proposals will be
consistent with the above changes proposed for the existing allocation process, for example,
recognising AGMI data as a separate allocation group.
We will consult with industry, via the AGMI working group and/or the DAWG, on the most
efficient process and format for providing AGMI data to the D+1 system.

24
 5. Alignment of GMSAs

Gas Metering Service Agreement (GMSA) terms could potentially be standardised

to remove barriers for new metering service providers entering the market and to
promote efficiency by lowering transaction costs for retailers and metering
service providers.

5.1 Issue
The metering service market (provision of hardware and data management) is not regulated as
it is not a monopoly business and in theory a competitive market should evolve over time.
However, there is a concern that due to the small size of the New Zealand market, only a small
number of participants will share the market and that the concentration of market power will
affect competition.
There is also currently no distinction between a metering equipment provider and the metering
owner as there is in the electricity industry. There is a much larger metering market in the
electricity industry and higher commercial value of metering information due to the very
different nature of the electricity market (reconciliation and clearing based on half-hour
metered consumption, TOU tariffs, spot exposure, future market, optimising operation of assets
etc) compared to the gas market.
However, the material alignment of core terms, for example in the Vector AMS template and
Powerco standard GMSA, include terms, service definitions and performance standards
expected in today’s market for any metering services show that commercial industry
agreements can be balanced and addressing these concerns.
Therefore, there is at this stage no evidence that regulatory intervention is necessary and more
standardised arrangements through a model GMSA, benchmark terms or contracting
principles are required.

5.2 Recommendation
At this point in time, Gas Industry Co doesn't see that there are material efficiency gains
through common GMSA terms. Gas Industry Co recommends that this issue can be revisited if
there is any evidence of inefficient market operation to the detriment of gas retailers or
consumers.
The Commerce Commission is aware of the issue of potential market power concentration and
continues to pay attention to the pricing of gas metering services in future, as they do with
pricing in any infrastructure sector where competition concerns have been identified. 9

9
https://comcom.govt.nz/__data/assets/pdf_file/0022/62572/Preliminary-assessment-of-whether-to-conduct-a-Part-4-
inquiry-into-gas-metering-services-1-April-2016.PDF

25
 6. GMSA payment provisions

Stakeholders were concerned that retailers’ obligation to pay for metering

services at a disconnected ICP could be introduced.

6.1 Issue
At this point it is unclear whether there is an issue. It is current industry practice that on the
disconnection of a gas customer’s ICP, the retailer’s obligation to pay for gas metering services
at that ICP is typically suspended until the ICP is reconnected. This is a pragmatic industry
practice which seems to work.
Any allocation of costs between retailers and meter owners/metering service providers is a
matter for those parties.

6.2 Recommendation
No action required. If issues flow down to consumer contracts, then a change to the Retail
Contracts Scheme could be considered.

26
 7. Cost and benefit to consumers

From a consumer perspective it is important that the deployment of advanced

gas meters increases market efficiency and that the benefits of deployment
outweigh the costs to end consumers.

7.1 Issue
Gas Industry Co considers it important to ensure that the increased benefits to end consumers
related to the deployment of AGMI outweigh any potential cost increase to these consumers.

However, the contestable nature of the market means that AGMI uptake will only become
ubiquitous if it lowers overall costs or adds significant benefits for retailers or their customers.
Gas Industry Co considers the benefits of a gas smart meter roll-out sit mainly with the retailers
and not with the consumer:
• avoided physical meter reads and related costs
• avoided HSE risks associated with physical meter reads
• better back-end integration (reconciliation, billing, switching, integration with electricity
billing systems)
• more accurate wholesale gas and network charge reconciliation
• more accurate annual UFG allocation
• more efficient balancing
These potential benefits suggest that these benefits more than outweigh the cost of AGMI
deployment costs, meaning that end consumers will not pay more for metering services,
despite potentially receiving an enhanced service. Due to the very different nature of the gas
market (no volatility due to contracted wholesale prices, no spot market exposure, etc.) to the
electricity market (cost reflective network pricing, potential exposure to 48 different spot prices
per day, load control capability, multiple traders on one ICP, etc.) gas smart meters do not
provide for the same consumer benefits as electricity smart meters do.
In the competitive gas metering market, it is up to retailers to improve internal processes by
using gas smart meter data to make a business case to potentially passing on cost savings for
their customers’ benefit.
In this context, a large Metering Service Provider (MSP) communicated that it does not intend
to charge a higher lease fee for advanced gas meters over existing meters where there is no
data service.

7.2 Recommendation
Gas Industry Co recommends keeping a ‘watching brief’ on the deployment of AGMI,
monitoring the relative costs and benefits to consumers. Any monitoring activity may require
retailers and MSPs, from time to time, to provide the relevant information to Gas Industry Co.

27
 8. AGMI redundancy risk

There is a risk that AGMI deployed now will become redundant before the end of
the useful economic life of that equipment, due to Government policy settings
aimed at phasing-out of fossil-fuel derived gas as a fuel source in New Zealand.

8.1 Issue
For capex decision, parties must weigh up benefits of AGMI vs expected lifetime of the asset.
Government policy settings in relation to terminating existing residential gas connections are
unclear at this point. The allocation of costs between retailers and meter owners reflecting a
potential redundancy risk is a matter for those parties. Ultimately the cost of that potential risk
will be passed on to consumers through gas retail pricing.

8.2 Recommendation
No action required. This issue can be revisited if there is a policy setting in place.

28
 9. Advanced meter displacement

The replacement of a smart meter by another smart meter provider before the
end of its economic life creates inefficiencies.

9.1 Issue
There is no regulation in the gas markets that prevents one MSP’s metering installation being
displaced by another MSP’s metering installation at an ICP. This is the case, when the
consumer switches its retailer, and the new retailer has a different MSP than the incumbent
retailer. It creates an economic inefficiency when a smart meter is replaced by another smart
meter before the end of its economic life.
Whilst Gas Industry Co notes the unregulated approach to this issue in the electricity market,
and the potential competition benefits of such an approach, Gas Industry Co believes that
there is a minor risk of economic inefficiency of replacing functional advanced metering
equipment with remaining economic life, with replacement advanced metering equipment.
However, given the much smaller size of the gas market (300,000 residential and small
commercial ICPs) compared to the electricity market (almost 2,000,000 residential ICPs), fewer
participants and a slower deployment rate, Gas Industry Co believes that there is no case for
regulatory intervention at this stage. Participants should be able to negotiate commercial
solutions if the issue becomes material.

9.2 Recommendation
Gas Industry Co proposes to keep a ‘watching brief ‘on advanced meter displacement activity
in the gas metering market to determine materiality of the issue requiring intervention.

29
 10. GMS ownership and standard

Gas meters form part of a wider gas measurement system (GMS). The
deployment of smart gas meters could result in split ownership GMSs, with the
MSP owning the meter and potentially the regulator, and the distributor owning
the balance of the GMS equipment.
10.1 Issue
Some distribution network companies may prefer to have ownership of the entire GMS at all
ICPs on their networks, as a single point of control might deliver efficiency and safety benefits
operating and maintaining the network and GMS infrastructure.
Thus, in the case of advanced gas meters deployed on these networks by a third-party MSP,
the network company would wish to become the advanced meter owner, to ensure the entire
GMS remains under the control of a single party.
On open access gas distribution networks, the retailer at an ICP can select its own MSP for the
ICP, in some cases resulting in split ownership GMSs, with the MSP owning the meter and
potentially the regulator, and the network company owning the balance of the GMS
equipment.
An MSP might carry out non-meter GMS work at an ICP, at the same time as it replaces the
legacy meter with an advanced gas meter, including upgrading inefficient gas venting valves
with more efficient gas overpressure valves, or making necessary safety modifications.
Necessary changes, whether required for safety or efficiency, to a GMS at the same time as the
installation of a new advanced gas meter is carried out is more efficient. The GMS owner’s
consent might be required for this work to proceed.
Gas Industry Co considers that GMS split ownership would not create significant operational
inefficiencies and there is no need to regulate GMS asset ownership.
Parties making non-meter GMS changes on third party distribution networks should have a
commercial agreement in place, covering in particular responsibility for the costs of these
changes, determining who will have ownership of the modified GMS, any reasonable exchange
of value between MSPs for legacy GMS equipment and determining when changes to a GMS
are able to be made to ensure a distribution network owner’s return on investment in a GMS is
not unnecessarily affected.
Gas Industry Co considers that detailed commercial arrangements required to address these
issues will evolve.

10.2 Recommendation
Gas Industry Co recommends monitoring competition in the market, the costs and benefits to
consumers and any impact of GMS ownership issues. In the case of ownership issues
potentially resulting in monopoly ownership structures blocking competition, regulatory
intervention might be required. However, decisions on the regulation of GMS providers under

30
part 4 of the Commerce Act is a question for Parliament and the Commerce Commission, not
Gas Industry Co.

31
 11. Advanced Metering consumer
education

Consumer education and communication plays an important role during

deployment of gas smart meters and should address commonly asked questions
about the technology helping consumers understand the importance of smart
meters and their benefits to people and the environment.

11.1 Issue
Whilst Gas Industry Co considers that the provision of educational advice forms part of its
function (see GPS Item 13 requiring Gas Industry Co to pursue outcomes where “The respective
roles of gas metering, pipeline and gas retail participants are able to be clearly understood”
and “Good information is publicly available on the performance and present state of the gas
sector” 10), it considers that retailers and industry associations such as GasNZ are well-placed to
perform this educational role.

11.2 Recommendation
Gas Industry Co recommends that retailers and GasNZ provide educational information to
consumers with the support of Gas Industry Co.

10
https://www.gasindustry.co.nz/assets/DMSDocumentsOld/rules-and-regulations/4791GPS-2008.pdf

32
 12. Market competition

The 2017 Gas Review found limited competition in the gas metering market, due
to retailers generally selecting the relevant distribution network owner’s MSP as
the metering service provider. 11

12.1 Issue
It was also noted there seem to be limited incentives on parties to contract separately for
distribution and metering services, as there is no real service differentiation between metering
providers, and there were efficiencies associated with combining the relationships. 12
Gas Industry Co considers that smart gas meters provide for the opportunity to develop a
service differentiation. The level of a potential service differentiation provided to retailers and
consumers may enhance the level of competition. However, Gas Industry Co is aware that the
very limited size of the market only allows for a very limited number of MSP. This issue should
be resolved by the market.

12.2 Recommendation
No action required. Gas Industry Co reiterates that it is supportive of industry-led market
settings that encourage increased competition, as these are consistent with its GPS efficiency
and fairness objectives. It also notes decisions on the regulation of GMS providers under part 4
of the Commerce Act is a question for Parliament and the Commerce Commission, not Gas
Industry Co.

11
Analysis of 17 months of registry data up to May 2016 confirms ~100% (> 99.9%) alignment between the MSP chosen by
retailers and the related network owner. Gas Metering Review – review of metering service provider arrangements, 1 March
2017, page 5.
12
Gas Industry Company Analysis of submissions and metering review, September 2017, page 1.

33
 13. Preferred supplier provisions in
legacy GSMAs

There are provisions in some legacy GSMAs related to a preferred supplier status
and/or first right of refusal extended to retailer-initiated third-party meter
replacements and upgrades.

13.1 Issue
These provisions oblige a retailer to choose a particular MSP for retailer-initiated third-party
meter replacements and upgrades. Generally, this would be the distribution networks preferred
MSP.
Any enforcement of this provision practically means that the retailer potentially cannot freely
choose its preferred MSP which would lead to further aggregation of the gas metering service
market, reducing competition.
Gas Industry Co is of the view that preferred supplier provisions could potentially be removed
by contracting parties from legacy GSMAs to increase competition. This is consistent with the
GPS efficiency and fairness objectives.

13.2 Recommendation
The terms and conditions of access to gas meters by gas retailers is a purpose for which gas
governance regulations may be made on the recommendation of the Minister (based on
recommendations made by Gas Industry Co (section 43G(2)(f) of the Gas Act).
At this stage Gas Industry Co has no evidence that the existence of these provisions is a major
issue requiring regulatory intervention.
Decisions on the regulation of GMS providers under part 4 of the Commerce Act are a question
for Parliament and the Commerce Commission. However, the Commerce Act applies only to
open access networks, so that excluded networks can not be regulated.

34
 14. Remote disconnections and
reconnections

Smart gas meters provide for the functionality of remotely

disconnecting/isolating and reconnecting supply to a gas installation. This
functionality has the potential to save operational costs but there is also an
inherent H&S risk associated with remote reconnections.

14.1 Issue
Participants would mainly use the disconnection/reconnection functionality to disconnect ICPs
from gas supply for non-payment and to reconnect supply accordingly.
Therefore, regulation 52A of the Gas (Safety and Measurement Regulations) 2010 applies in
cases of a reconnection of gas supply to a gas installation on which no general or high-risk
gasfitting work has been done.
Regulation 52A requires a person reconnecting or restoring gas supply to a gas installation
to rely in good faith on written confirmation by the owner that no gasfitting work has been
undertaken during disconnection/isolation;to ensure safe operation of the installation following
reconnection;
• to immediately disconnect if the gas installation is not operating in a safe manner.
The remote disconnection/isolation process is not prohibited under the regulatory framework
as it is not considered as being “gasfitting” under the definition in section 5 of the Plumbers
Gasfitters, and Drainlayers Act 2006.
However, regulation 52A was designed to require physical presence of the person reconnecting
but doesn’t explicitly exclude that a reconnection, safe operation check and immediate
disconnection in case of unsafe operation can’t be done with the person undertaking these
compliance requirements not to be on-site.
Managing the Health and Safety risk

The remote reconnection of gas supply to a gas installation carries an inherent H&S risk which
needs to be minimised in case of remote operation of the meter. The safety check before and
after reconnection required under regulation 52A relates for example to the safe reconnection
of appliances, the check of older appliances before relighting them, and general safety of the
installation. In theory, these checks could be carried out remotely with the customer
communicating online with qualified staff via smart phone. Gas Consumer Care Guidelines 13
already provide the expectation that “Remote Gas reconnections should only occur if the Retailer
can reasonably satisfy itself that the reconnection can be completed safely.”

13
https://www.gasindustry.co.nz/assets/CoverDocument/Gas-Consumer-Care-Guidelines.pdf

35
The development of a standard processe agreed by market participants (MSPs, retailers,
network owners) for the safe disconnection and reconnection of gas ICPs, through the remote
disconnection and reconnection functions in advanced gas metering, could address the H&S
aspects of the reconnection and help to facilitate the timely delivery of the benefits which may
flow from this technology.
Even with the strictest procedures detailing the remote reconnection process there will always
be a residual risk.
It is worth noting that Ofgem (UK) confirmed that there have been zero remote disconnections
and reconnections for gas smart meters carried out by gas retailers since Ofgem began to
collect data on this issue in 2016.

14.2 Recommendation
Gas retailers confirmed that even if it would be possible to design a process to remotely
reconnect, they are currently not willing to take the inherent risk of a reconnection under H&S
aspects, and consequently no action is required at this stage.
Participants suggested that it would be useful to clarify what qualification a person would be
required to hold to reconnect a gas installation on site. As the reconnection is potentially not
gas fitting work, the specific task could potentially be carried out by a person other than a
qualified gasfitter but specifically trained to do this kind of work.
This would require the industry to engage with Worksafe and the Plumbers, Gasfitters and
Drainlayers Board. If needed, Gas Industry Co could support this process in a facilitating role.

36
 15. Multiple trading relationships

The Electricity Authority identified that the restriction to only one trader per ICP
was a barrier for the introduction of innovative products in the electricity industry
but there is currently no regulation in place to enable MTR in the electricity
sector.

15.1 Issue
The structure of the electricity market, in particular the half-hour spot pricing in the wholesale
market, the capability of residential ICPs to participate in demand side response and the
options around selling electricity back to the network provide many opportunities for
consumers using smart meter functionalities to choose innovative products from retailers and
service providers, which enhances competition in the retail market.
The gas market lacks this flexibility. Gas Industry Co can’t see a viable use case for multiple
trading relationships in the gas retail market.

15.2 Recommendation
No action required. For the time being we will continue to assess making changes where there
is a clear benefit.

37
 16. Critical Contingency Regulations

Gas smart meters have the functionality of remotely disconnecting and could
support curtailment in a critical contingency event.

16.1 Issue
This functionality could potentially be used to curtail load under schedule 3 of the Gas
Governance (Critical Contingency Management) Regulations 2008 (CCM Regulations) in case
of a critical contingency event. Curtailment of band 6 includes small commercial consumers.
However, the purpose of the CCM Regulations, amongst other, is to achieve the effective
management of critical gas outages and pipeline events. These events are managed by the
CCO and potentially require curtailment of larger loads first.
The load curtailment, which could potentially be provided by small commercial consumers is so
small that it is neither pragmatic nor effective to design rules regulating small consumer
curtailment by using a gas smart meter.
The H&S aspect discussed above in section 14, would require physical presence for a
reconnection. This means that the reconnection of many very small loads would take a long
time associated with high operational costs and, therefore, would be inefficient.

16.2 Recommendation
No further action required.

38
About Gas Industry Co
Gas Industry Co is the gas industry
body and co-regulator under the
Gas Act. Its role is to:

• Develop arrangements,
including regulations where
appropriate, which
improve:
o the operation of gas
markets;
o access to infrastructure;
and
o consumer outcomes;

• Develop these
arrangements with the
principal objective to
ensure that gas is delivered
to existing and new
customers in a safe,
efficient, reliable, fair and
environmentally
sustainable manner; and
• Oversee compliance with,
and review such
arrangements.
Gas Industry Co is required to
have regard to the Government’s
policy objectives for the gas sector,
and to report on the achievement
of those objectives and on the
state of the New Zealand gas
industry.

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By 5pm Monday 4 [email protected] [email protected]
September 2023

p. +64 4 472 1800 • [email protected] • gasindustry.co.nz

Level 10, Brandon House, 149 Featherston Street, PO Box 10-646, Wellington 6140

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