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Essential Services Commission

Retailer of Last Resort Manual

Electricity or Gas RoLR event triggered by

the Australian Energy Market Operator

Version 4

August 2011

2

Preface

Under the Electricity Industry Act 2000 and the Gas Industry Act 2001, the retailer of last resort (RoLR) scheme can be triggered by the Essential Services Commission (ESC) through licence revocation or by the Australian Energy Market Operator (AEMO).1 AEMO can suspend a retailer from purchasing electricity or gas in the wholesale market if a retailer cannot satisfy AEMO’s prudential requirements. This procedural manual relates only to a retailer failure triggered by AEMO and sets out:

the processes the ESC will follow and

the role of AEMO, distributors, RoLRs and the failed retailer before, during and after the RoLR event.

The procedural manual should be reviewed and amended as the need arises so that if a RoLR event should occur the risk of using outdated procedures is minimised

1 On 1 January 2009, the Australian Energy Market Operator subsumed the role of the NEMMCO in the

national wholesale electricity market and VENCorp in Victoria’s gas wholesale and retail market.

3

CONTENTS PAGE

Preface .............................................................................................................................................. 2

Background ...................................................................................................................................... 4

ESC checklist for a RoLR event ..................................................................................................... 7

RoLR Overview Diagram .............................................................................................................. 18

Detailed customer transfer process in electricity industry ...................................................... 19

Diagram 1: ESC and AEMO process prior to suspension of retailer in the electricity industry

......................................................................................................................................................... 20

Diagram 1A: ESC and AEMO process prior to suspension of retailer in the gas industry ... 21

Diagram 2: Customer transfer process after RoLR was invoked ............................................. 22

Diagram 2A(1): Distributors’ process for transferring customers’ data after an electricity

retailer has been suspended ........................................................................................................ 23

Diagram 2A(2): Distributors’ process for transferring customers’ data after a gas retailer

has been suspended ..................................................................................................................... 24

Diagram 2B: Failed retailer’s process for transferring customers’ data upon suspension .. 25

Diagram 2C: RoLRs process for receiving the failed retailer’s customers’ data ................... 26

Diagram 3: Information flow from the ESC to RoLR following retailer suspension ............... 27

Diagram 3A: Information flow from RoLRs to the ESC following retailer suspension .......... 28

Diagram 4: Information flow between the ESC and distributors following retailer suspension

......................................................................................................................................................... 29

Diagram 5: ESC process for communicating with call centre .................................................. 30

Diagram 6: ESC process for communicating with Energy and Water Ombudsman, Victoria

(EWOV) ........................................................................................................................................... 31

Diagram 7: ESC process of monitoring RoLRs performance ................................................... 32

Attachment 1 – RoLR Order in Council ....................................................................................... 33

Attachment 2 – Contact list .......................................................................................................... 34

Attachment 3 – ESC AEMO RoLR communication protocol for the electricity industry ....... 37

Attachment 4 – ESC AEMO RoLR communication protocol for the gas industry .................. 55

Attachment 5 – RoLR media template ......................................................................................... 67

Attachment 6 – Letter and notification templates ...................................................................... 69

Attachment 7 – RoLR questions & answers ............................................................................... 74

Attachment 8A – ESC RoLR briefing document for an electricity RoLR event ...................... 78

Attachment 8B – ESC RoLR briefing document for a gas RoLR event ................................... 79

Attachment 9 – ESC, EWOV and RoLR protocol for handling customer queries/complaints

during a Retailer of Last Resort event ........................................................................................ 80

Attachment 10 – Approved RoLR tariff terms and conditions ................................................. 82

Attachment 11 – Customer information template for data custodians .................................... 83

Attachment 12 – ESC checklist for a RoLR event ...................................................................... 84

4

Background

Legislative framework

Part 2 division 8 of the Electricity Industry Act 2000 (EI Act) and part 3 division 6 of the Gas Industry Act 2001 (GI Act) establish a retailer of last resort (RoLR) scheme for electricity and gas in Victoria. A RoLR scheme in the electricity and gas sectors is intended to maintain continuity of electricity and/or gas supplies to the premises of both small and large customers (that is, regardless of whether the customer is a large business or small business or a resident) by requiring another retailer to sell electricity and/or gas to these customers when their existing retailer is unable to do so. The event that will trigger the operation of the RoLR scheme in the electricity industry as specified in the EI Act is when:

a retailer’s licence is revoked or

a retailer’s right to acquire electricity in the wholesale market is suspended.2 The event that will trigger the operation of the RoLR scheme in the gas industry as specified in the GI Act is when:

a retailer’s licence is revoked or

a retailer has been deregistered as a market participant in the category of retailer under the National Gas Rules after a notice of suspension was issued by AEMO.3

The EI and GI Acts also specify that:

The failed retailer, or its insolvency official, must provide relevant customer data to the RoLR at the request of the ESC or the RoLR.

The RoLR must supply or sell electricity and/or gas at tariffs and on terms and conditions approved by the ESC to the failed retailer’s residential and small business customers. The failed retailer’s large business customers – those consuming more than 160 MWh of electricity or 5 TJ of gas – will need to negotiate their individual tariffs, terms and conditions with the RoLR directly.

The RoLRs’ obligation to supply or sell electricity and/or gas to all customers of the failed retailer ends:

3 months after its commencement

when the customer advises that the supply or sale is no longer required

when the customers transfers to become the customer of another licensee or

when the customer enters into a new contract with the RoLR for the supply or sale of electricity

whichever occurs first.

ESC’s final decision

Under the EI and GI Acts, the ESC has broad discretion to develop and implement the electricity and gas RoLR schemes. The ESC released its final decision on an energy RoLR scheme in February 2006. Below is a summary of that final decision.

2 Section 49D(5) of the EI Act.

3 Section 51D(5) of the GI Act.

5

Local retailer failure

The ESC’s key final decision is:

In the event of a local retailer failure in the electricity industry, the remaining local retailers in Victoria would provide the RoLR service for all the customers of a failed local retailer. Customers of the failed local retailer would be allocated to the remaining local retailers on the basis of TNIs and market share.

In the event of a local retailer failure in the gas industry, customers of the failed local gas retailer will be allocated to the other local gas retailers within the relevant gas distribution network area.

Non-local retailer failure

The ESC’s key decisions in relation to a non-local retailer failure were:

In the electricity sector, local retailers should be assigned initial responsibility for operation of a RoLR scheme in their local area.

In the gas sector, the host retailers will be assigned RoLR obligations in their host area.4

The RoLRs’ tariffs, terms and conditions for the supply and sale of electricity and/or gas would apply to customers with annual electricity consumption of less than 160 MWh or annual gas consumption of less than 5,000 GJ.

A meter reading or meter estimate will be made on the date that the RoLR commenced.

As soon as practicable after becoming aware of a last resort event having occurred, the RoLR must provide each of its RoLR customers specified information in writing.

Roles and responsibilities in a RoLR event

Below is an overview of the roles and responsibilities of key parties during a RoLR event. ESC:

To make sure that a RoLR instruction is clearly conveyed to AEMO

To notify the RoLR/s and distributors of a RoLR event

To brief the media, the Minister for Energy, the Department of Primary Industries and EWOV on the RoLR event

To monitor the progress of all relevant parties during a RoLR event, and take corrective action where progress is inadequate

To communicate with customers impacted by the RoLR event AEMO:

Maintain the integrity of market payments and take corrective action where necessary in accordance with the National Electricity Rules and the National Gas Rules

Carry out the transfer of customers from a failed retailer to the RoLRs under instruction from the ESC

In the case of gas and in the event that the failed retailer refuses to do so, as the data custodian, provide data consistent with the customer information template (at attachment 11) to the RoLRs to allow them to carry out their RoLR obligations

Failed retailer:

Provide customer information to the RoLRs at the request of the RoLRs or the ESC

4 Host retailers’ geographic area are aligned with the distribution network area.

6

Meter data provider (if the meter data provider is not a distributor):

Ensure a meter reading or estimate is made for the failed retailer’s customers at the time that their existing retailer fails

Distributor:

In the case of electricity and in the event that the failed retailer refuses to do so, as the data custodian provide data consistent with the customer information template (at attachment 11) to the RoLRs to allow them to carry out their RoLR obligations

As Responsible Person, ensure that a meter reading or an estimate is made for the failed retailer’s customers at the time that their existing retailer fails

RoLR:

Become financially responsible to AEMO for the purchase of sufficient quantities of electricity and/or gas to supply the failed retailer’s customers

Provide information to the failed retailer’s customers as soon as practicable after RoLR has been invoked

Sell electricity or gas to the failed retailer’s customers .

7

ESC checklist for a RoLR event

The checklist in the following pages sets out what the ESC has to do, in chronological order, before, during and after a RoLR event. The key steps of a RoLR event in this checklist are:

regular customer data transfers to the data custodians

actions leading to an AEMO triggered RoLR event in the electricity industry

actions leading to an AEMO triggered RoLR event in the gas industry

procedures when RoLR event is triggered for the electricity industry

procedures when RoLR event is triggered for the gas industry

procedures involving the failed retailer, the ESC’s call centre and EWOV when RoLR event is triggered

actions after RoLR event has been invoked and

actions at the conclusion of the RoLR period. Additional copies of this checklist are in Attachment 12 for staff use during a RoLR event.

8

1. Regular customer data transfer to data custodians

The data custodian for electricity customer information is the distributor and for gas customer information the data custodian is AEMO. If the failed retailer does not provide the customer information to the RoLRs, the data custodian is required by legislation to provide this information to the RoLRs (using the customer information template in Attachment 11).

ESC checklist:

Data custodians confirm with RoLR Contact Officer at periodic intervals that customer

database is up-to-date

9

2. Actions leading to a RoLR trigger event

2.1 Procedures involving AEMO for an electricity RoLR trigger event

a) AEMO issues a Call Notice to the retailer if their outstanding payments are greater than their Trading Limit, as described in Attachment 3. AEMO also provides a copy of the Call Notice to the ESC in accordance with the Standing Request for Information

ESC checklist:

ESC RoLR Contact Officer receives verbal advice from AEMO regarding the issuing of a

Call Notice as well as a copy of the Call Notice via email, according to the Standing

Request for Information (at Attachment 3)

If there is media speculation about possible failure of retailer:

ESC RoLR Contact Officer verbally advises ESC CEO and Communications Manager of

media query

ESC CEO makes decision on how to respond

b) If a retailer fails to respond adequately to AEMO’s Call Notice, a default event has occurred

as defined in the NER, and AEMO issues a Default Notice to the retailer and provides a copy to the ESC in accordance with the Standing Request for Information (at Attachment 3).

ESC checklist:


Default Notice as well as a copy of the Default Notice via email, according to the

Standing Request for Information at Attachment 3

ESC RoLR Contact Officer reviews the RoLR procedures in this manual in preparation

for the RoLR event

ESC RoLR Contact Officer verbally advises the following

Internal staff: CEO, Commissioners, the Communications Manager and Compliance

Manager

External stakeholders: Department of Primary Industries and the Minister for Energy’s

Advisor. Their contact information is at Attachment 2

c) If the retailer’s response to the Default Notice is not adequate, AEMO’s Prudential Committee

meets to consider suspending the retailer. At this time, AEMO informs the ESC only of the date and time of the meeting, but not who the retailer is.

ESC checklist:

ESC RoLR Contact Officer phones local retailers (AGL, Origin and EnergyAustralia)

and distributors informing of potential RoLR event and noting that the identity of the

failed retailer is unknown at this time. The contact information for the local retailers’ and

distributors’ staff are at Attachment 2


for the RoLR event

2.2 Procedures involving AEMO for a gas RoLR trigger event

d) If a retailer reaches or exceeds its trading limit, AEMO issues a Margin Call to the retailer or if a retailer does not pay money owing or provide credit support as required by the National Gas Rules, AEMO issues a Default Notice to the retailer. AEMO also provides a copy of the

10

Margin Call or Default Notice to the ESC in accordance with the Standing Request for Information (at Attachment 4)

ESC checklist:


Margin Call, as well as a copy of the Margin Call via email, according to the Standing

Request for Information (at Attachment 4), or


Default Notice, as well as a copy of the Default Notice via email, according to the

Standing Request for Information (at Attachment 4)

If there is media speculation about possible failure of retailer:

ESC RoLR Contact Officer verbally advises CEO and Communications Manager of

media query

ESC CEO makes decision on how to respond

e) If the retailer does not respond adequately to the Margin Call or Default Notice, AEMO issues

a Suspension Notice to the retailer. As AEMO is required under rule 260 of the National Gas Rules to publish the suspension notice, the failed retailer will be known at this time.

ESC checklist:


Suspension Notice and receives a copy of the Suspension Notice via email according to

the Standing Request for Information (at Attachment 4)

ESC RoLR Contact Officer advises the following internal staff: CEO, Commissioners,

the Communications Manager and Compliance Manager

ESC RoLR Contact Officer advises the following external stakeholders: Department of

Primary Industries and the Minister for Energy’s Advisor. Their contact information is at

Attachment 2


for the RoLR event

ESC RoLR Contact Officer phones local retailers (AGL, EnergyAustralia ad Origin) and

distributors informing of potential RoLR event. The contact information for the local

retailers’ and distributors’ staff are at Attachment 2

If revocation of registration is imminent AEMO will phone ESC RoLR Contact Officer to

advise that a RoLR event is imminent. It gives date and time of intended revocation of

registration and RoLR transfer initiation information

11

3. Actions when RoLR event is invoked

3.1 Procedures involving AEMO for an electricity RoLR event

a) If AEMO’s Prudential Committee issues a Suspension Notice to the retailer, it provides a copy to the ESC (all market participants are notified that a Suspension Notice has been issued to the retailer). Issuance of the Suspension Notice triggers a RoLR event and initiates the following series of procedures:

ESC checklist:


Suspension Notice as well as a copy of the Suspension Notice via email, according to the

Standing Request for Information (at Attachment 3)

ESC RoLR Contact Officer informs the CEO, Commissioners, the Communications

Manager, Department of Primary Industries and the Minister for Energy’s Advisor using

the briefing document in Attachment 8A. Contact information for DPI and the Minister

for Energy’s Advisor is at Attachment 2.

ESC RoLR Contact Officer and Communications Managers prepare newspaper

advertisement and media release (in Attachment 5)

ESC RoLR Contact Officer telephones distributors and RoLRs to provide specific details

of the RoLR event followed by email confirmation using the relevant templates in

Attachment 6. Contact details for distributors and RoLRs can be found in Attachment 2

ESC RoLR Contact Officer telephones failed retailer to obtain further information and

remind it of its obligations under the EI Act to provide customer data to the RoLR or

ESC, which should be followed up with email confirmation

If AEMO revokes the Suspension Notice, informs RoLR Contact Officer, the CEO,

Commission, the Communications Manager, Department of Primary Industries and

Minister for Energy’s Advisor

ESC Communications Manager:

Informs Minister for Energy’s media advisers

Reviews media coverage in the immediate aftermath of the announcement

Consults with Minister for Energy’s office, Commission and DPI staff

Plans for the next possible public announcements

b) AEMO transfers RoLR customers to RoLRs according to the AEMO – ESC RoLR

Communication Protocol for an electricity RoLR event at Attachment 3

ESC checklist:

AEMO phones ESC RoLR Contact Officer to advise that it will send NMIs of the failed

retailer’s customers

ESC RoLR Contact Officer receives a RoLR initiation advice from AEMO which

indicates the approximate time that AEMO will initiate the RoLR transfer, confirmation

of the total number of customers to be transferred and estimated program for the transfer

(see the AEMO – ESC RoLR Communication Protocol in Attachment 3)

AEMO advises ESC RoLR Contact Officer when transfers have been initiated in

MSATS, and provides email confirmation that transfers have been completed

12

3.2 Procedures involving AEMO for a gas RoLR event

a) If the retailer does not respond adequately to the Suspension Notice, AEMO revokes the registration of the suspended retailer. It also provides a copy of the Suspension Notice to the ESC. Issuance of a Suspension Notice triggers a RoLR event if AEMO does not revoke the Suspension Notice by the specified date. This initiates the following series of procedures

ESC checklist:


Suspension Notice and receives a copy of the Suspension Notice via email according to

the Standing Request for Information (at Attachment 4). If the Suspension Notice is not

revoked by the specified date, AEMO also advises the ESC that the retailer’s registration

has been suspended

ESC RoLR Contact Officer informs the CEO, Commissioners, the Communications

Manager, Department of Primary Industries and the Minister for Energy’s Advisor using

briefing document in Attachment 8B (refer to Attachment 2 for contact details)

ESC RoLR Contact Officer and Communications Manager prepare a newspaper

advertisement and media release (in Attachment 5)

ESC RoLR Contact Officer telephones distributors and RoLRs to provide specific details

of the RoLR event followed by email confirmation using the relevant templates in

Attachment 6. Contact details for distributors and RoLRs can be found in Attachment 2

ESC RoLR Contact Officer telephones failed retailer to remind it of its obligations under

the GI Act to provide customer data to the RoLR or ESC and follows up with email

confirmation

ESC Communications Manager:

Informs Minister for Energy’s media advisers

Reviews media coverage in the immediate aftermath of the announcement

Consults with relevant Minister for Energy’s office, Commission and DPI staff

Plans for the next possible public announcements

b) AEMO transfers RoLR customers to RoLRs according to the AEMO – ESC RoLR

Communication Protocol for a gas RoLR event at Attachment 4

ESC checklist:

AEMO advises ESC RoLR Contact Officer when RoLR transfers will be initiated in the

metering and settlement systems

ESC RoLR Contact Officer receives a RoLR initiation advice which indicates the

approximate date and time that the retailer will be suspended and initiate the RoLR

transfer. This advice should contain confirmation of the total number of customers

impacted and the time expected to complete the program of transfer (refer to AEMO –

ESC RoLR Communication Protocol for a gas RoLR event at Attachment 4

AEMO advises ESC RoLR Contact Officer via email that RoLR transfers have been

completed

13

3.3 Procedures involving failed retailer

a) Failed retailer provides complete customer information to the RoLRs within two business days after receiving a request (from the RoLR or the ESC) for the customer information

ESC checklist:

ESC RoLR Contact Officer confirms with failed retailer whether it has sent customer

information to the RoLR

ESC RoLR Contact Officer confirms with RoLR whether it has received complete

customer details and billing information from the failed retailer

If failed retailer does not provide customer details to the RoLRs:

ESC RoLR Contact Officer considers what action to be taken to facilitate and enforce the

failed retailer’s obligation under the legislation to produce customer information

ESC RoLR Contact Officer advises the RoLRs that data custodians – distributors (for

electricity) and/or AEMO (for gas) – will provide the customer information as contained

in the customer information template at Attachment 11

Data custodians confirm with ESC RoLR Contact Officer that customer information has

been provided to RoLRs

3.4 Procedures involving estimated meter reads

a) For electricity, AEMO requests Meter Data Providers to provide estimated meter reads for each NMI according to AEMO’s RoLR Guidelines and the NEM Metrology Procedure, but by no later than close of business of the second business day. Metering Data Providers provide meter reads to relevant distributors, AEMO for the purpose of settlement and to the failed retailer for the purpose of billing and the RoLRs for the purpose of account set-up and future billing.

ESC checklist:

AEMO, failed retailer, RoLRs and distributors confirm with ESC RoLR Contact Officer

that they have received meter data

b) For gas, AEMO requests distributors to provide it with estimated meter reads. Distributors

transfer estimated meter reads to AEMO and the RoLRs.

ESC checklist:

AEMO and RoLRs to notify ESC RoLR Contact Officer that they have received meter

data from the distributors

c) Distributors and RoLRs receive notification from AEMO that the customers of the failed

retailer have been transferred to the RoLRs

ESC checklist:

AEMO advises when RoLR transfers will be initiated in the metering and settlement

systems

AEMO advises ESC RoLR Contact Officer via email that transfers of failed retailer’s

customers have been completed

14

3.5 Procedures involving the ESC’s call centre and EWOV

a) ESC RoLR Contact Officer provides written advice to its call centre

ESC checklist:

ESC RoLR Contact Officer advises its call centre about the RoLR event using Template

6 in Attachment 6. It also provides the Q&As in Attachment 7

ESC maintains regular contact with its call centre

b) ESC RoLR Contact Officer provides written advice to EWOV

ESC checklist:

ESC RoLR Contact Officer advises EWOV of RoLR event using Template 7 in

Attachment 6, together with the Q&As in Attachment 7

ESC maintains regular contact with EWOV

15

4. Actions after RoLR event has been invoked

These actions are expected to be undertaken approximately one week after the RoLR event was invoked. a) RoLRs notify ESC that RoLR customer data has been received from failed retailer or data

custodian (if failed retailer is not cooperative); and that it has received estimated metering data from distributors.

ESC checklist:

ESC ensures notification of successful transferral of customer information is received

from RoLRs

If information transfers have not been successful, ESC enters into dialogue with

stakeholders to resolve any problems

ESC informs the CEO and Commissioners that customers and customer information of

the failed retailer have been successfully transferred to RoLRs

b) Distributors update their customer database with details about estimated reads and transfers

NMIs to the RoLRs

ESC checklist:

ESC receives confirmation from distributors that their customer databases have been

updated and RoLRs have received NMIs

c) RoLRs send a letter to customers informing them that they are the RoLR

ESC checklist:

ESC RoLR Contact Officer consults with RoLRs about the ESC’s letter to RoLR

customers (Template 2 in Attachment 6)

RoLRs send letter (agreed with the ESC) informing RoLR customers of their role as

RoLR together with the ESC’s letter. ESC RoLR Contact Officer ensures it receives a

copy of the letter that is sent to RoLR customers

d) ESC monitoring complaints and enquiries from customers to determine if action, if any, is to

be taken

ESC checklist:

ESC meets with its call centre on a regular basis to discuss enquiries/complaints received

ESC has regular discussions with EWOV about RoLR related enquiries/complaints

ESC writes to RoLR about systemic enquires/complaints it becomes aware of, and RoLR

confirms when problems are rectified.

16

4.1 RoLR customer transfers and communication

These actions are expected to be undertaken from approximately one week to three months after the RoLR event was invoked. a) RoLRs ensure that no systemic problems arise throughout the three months during which

they act as RoLR. If problems arise, RoLRs work with the ESC to resolve them

ESC checklist:

ESC must be notified by the RoLR if any problems or systemic issues arise during the

RoLR period, and the ESC must be consulted about problems and informed when they

are resolved

b) RoLRs send customers a single RoLR bill including the supply fee (if RoLRs choose to

charge the supply fee)

ESC checklist:

RoLRs notify ESC RoLR Contact Officer that final bills have been sent to RoLR

customers

c) Failed retailer prepares final bills and sends them to customers

ESC checklist:

Failed retailer notifies ESC RoLR Contact Officer that final bills have been sent to

customers

17

5. At the conclusion of the RoLR period (after three months)

a) RoLRs notify the ESC RoLR Contact Officer that the RoLR period of 3 months has ended and that all customers have been transferred off RoLR tariffs

ESC checklist:

ESC RoLR Contact Officer confirms with RoLRs that all customers have been

transferred off the RoLR tariffs, terms and conditions

b) ESC RoLR Contact Officer notifies all involved parties that the RoLR period of 3 months has

ended

ESC checklist:

ESC RoLR Contact Officer contacts:

the following external parties involved in the RoLR process to advise that the 3 month

RoLR period has ended: the Department of Primary Industries, the Minister for Energy’s

Advisor, AEMO, distributors and EWOV

the following internal parties that the 3 month RoLR period has ended: Chairperson,

CEO, Communications Manager and Compliance Manager

c) ESC RoLR Contact Officer arranges for a review of the RoLR event to be conducted

ESC checklist:

ESC lists and evaluates complaints/enquiries received by ESC, EWOV and RoLRs, and

information on action taken by RoLRs to rectify problems

ESC considers whether communications between the failed retailer and customers/ RoLR

and customers were clear and caused no confusion for customers

ESC evaluates whether communications between RoLRs, distributors, market operators,

Government agencies and customers were adequate

ESC considers whether RoLR experienced negative impact to business (i.e. call

management and work loads)

ESC Chairperson reports to the Minister for Energy and the Department of Primary

Industries on the effectiveness of RoLR event if appropriate

18

RoLR Overview Diagram

RoLR Event

Notification

Customer Transfers

(Gas)

Wholesale Markets

Customer Transfers

(Electricity)

1a AEMO advise market participants and ESC in accordance with protocols

2a(1a) AEMO suspends failed retailer in market systems. Thereby preventing all transfers to the failed retailer completing

2b(1) AEMO delivers a list of sites and requests the associated DB to provide an estimated read

2b(2) AEMO delivers a list of sites (both interval and basic meters) & associated BI &TSF by MIRN & summarised load data to the RoLR to assist with forecasting portfolio load going forward

2c(1) DB provide standing data to RoLR for account creation processing

2c(2) DBs provide estimated reads backdated as at the start of the RoLR event for basic meter sites to AEMO and RoLR

2e(1) RoLR establishes accounts in CIS and commences customer billing arrangements

2e(2) All DBs establishes new FRO in Asset Systems and commences network billing arrangements

All RBs to provide AEMO with std monthly file with data to support account

creation in CIS

2(1)a AEMO transfers failed Retailer sites to ROLR and notifies ESC of success or failure of transfer

2(1)d AEMO issues NMI lists to all affected participants and service providers. (incl MSATS notifications where Reqd)

2(1)f AEMO requests MDPs to provide estimate reads to participants to support ROLR date.

2(1)e ESC requests DBs to provide customer billing data to RoLRs 2(1)i RBs, DBs

and AEMO establishes RoLR customers in their systems

All RBs to provide DBs with a customer name, billing address list each

month

3 Procedures to be determined

Prudential Management 5a AEMO monitors prudentials

5b RoLRs update prudentials

5c Normal prudential management requirements

Suspension notification 6a AEMO publishes notice of suspension in newspapers next business day

Customer notification 7 Coordinate customer notification

1c ESC liaison with Minister for Energy, Department of Primary Industries and EWOV

2(1)c AEMO stops all transfers in progress to failed retailer and accelerates transfers away from failed retailer

2(1)b AEMO updates RP changes consistent with ROLR changes

2a(1b) AEMO accelerates transfers away from failed retailer

Service Orders 4 Procedures to be determined

2(1)g DBs provide list of customer billing details to ROLR participant.

2c(3) AEMO provides std customer billing data to RoLR for account creation processing

2a(2) AEMO updates FRO to RoLR where existing FRO is the failed retailer

19

RoLR Event Day 0

Industry Notification

(Electricity)

1a AEMO advises ESC in accordance with protocols. AEMO advises industry stakeholders (general notification) D0

2d AEMO delivers a list of sites and requests the associated MDPs to provide an estimated read Timing is volume dependent Manageable volumes visible from D1

2i Data Custodians (DBs) provide customer data to RoLR for account creation processing within 2 business days D1 (dependent on reconciliation / matching procedures undertaken)

2j MDPs provide estimated reads as at the end of Day 0 (day of RoLR event) for basic meter sites to AEMO, RoLR and failed retailer D4 – D7 (volume dependent)

2k RoLR establishes accounts in CIS and: Notifies customers (before first bills sent); and Commences customer billing arrangements – billing to begin on next scheduled read D7+ (Potential mismatches between data sources to be addressed by reconciliation / matching procedures to be determined)

2h DBs establish new FRMP in systems and commences network billing arrangements Bills for read on D1 to be delivered in accordance with normal billing cycle

1b ESC liaison with Minister and Department and EWOV D0

1d ESC and AEMO notify DBs and ROLRs (specific notification including No Action letters as req’d) D0

Customer Transfers

(Electricity)

AEMO performs RoLR processes including: 2a Stops all transfers in progress to FRB and accelerates transfers away from FRB to new FRMP Effective D0 Visible D0 / D1 2b AEMO generates transfer on estimate and updates FRMP to RoLR where existing FRMP is the failed retailer and updates Responsible Person accordingly Performed from D1 early Visible D1 2c Send Transfer Notifications (including C4 Report) where required. Performed from D1 early Visible D1 to D6 (volume dependent)

2e AEMO delivers a list of sites (both interval and basic meters) & summarised load data to the RoLR to assist with forecasting portfolio load going forward Visible from D1

2f AEMO delivers a list of sites (both interval and basic meters) to ESC From D1

2g MDPs (and MDAs) establish new FRMP in systems and commence data delivery Timing is volume dependent Manageable volumes: scheduled reads for D1 delivered in accordance with agreement with RoLR

1f FRB transfers customer data to RoLRs D1 onwards (2 business

days to complete)

Day 0 is the day when the Suspension Notice is effective midnight that day.

1c ESC notifies FRB of obligations D0

AMENDMENT RECORD

Version No.: Date:

1 23/10/2007

1e RoLR notifies FRB of obligations and requests transfer of customer data

D0

Detailed customer transfer process in electricity industry

20

Diagram 1: ESC and AEMO process prior to suspension of retailer in the electricity industry

Purpose of this diagram is to show the processes the ESC and AEMO RoLR contact officers are to follow when a retailer fails to satisfy AEMO’s prudential requirements.

1 Defined in the National Electricity Rules

Retailer must respond in one day

Retailer must respond in one day

ESC RoLR Contact Officer is informed by AEMO that the default has been resolved

ESC RoLR Contact Officer is informed by AEMO that Prudential Committee is meeting

AEMO informs ESC RoLR Contact Officer that the Board did not

approve suspension

RoLR Invoked

(See Diagrams 2, 3, 4, 5, 6, 7 and 8 for processes after the retailer has been suspended)

ESC RoLR Contact Officer receives a call notice

1 from AEMO

ESC RoLR Contact Officer receives a default notice

1 from AEMO

ESC RoLR Contact Officer notifies distributors and RoLRs of potential RoLR event providing only general details

If there is media speculation, ESC RoLR Contact Officer advise CEO and Communications Manager of the media interest

ESC RoLR Contact Officer briefs CEO, Commissioners, the Communications Manager, DPI and the Minister’s advisor

ESC RoLR Contact Officer informs CEO, Commissioners, DPI and Minister’s advisor (use RoLR

event briefing document at Attachment 8A)

ESC RoLR Contact Officer and Communications Manager prepare newspaper ad and media release

(at Attachment 5)

ESC RoLR Contact Officer check that the ESC is ready for the RoLR event

If AEMO decides to suspend, AEMO provides ESC RoLR Contact Officer with a

copy of the suspension notice

ESC RoLR Contact Officer notifies distributors and

RoLRs that suspension was not

approved

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Diagram 1A: ESC and AEMO process prior to suspension of retailer in the gas industry

Purpose of this diagram is to show the processes the ESC and AEMO RoLR contact officers are to follow when a retailer fails to satisfy AEMO’s prudential requirements.

ESC RoLR Contact Officer receives a copy of suspension notice that AEMO

issued to retailer

AEMO informs ESC RoLR Contact Officer suspension notice has been revoked

If retailer does not resolve prudential requirement by the specified date in the Suspension Notice, AEMO informs ESC RoLR Contact Officer

that Suspension Notice is not revoked

RoLR Invoked

(See Diagrams 2, 3, 4, 5, 6, 7 and 8 for processes after the retailer has been suspended)

ESC RoLR Contact Officer receives a copy of margin call that AEMO issued to retailer

ESC RoLR Contact Officer receives a copy of default notice AEMO issued to retailer

ESC RoLR Contact Officer notifies distributors and RoLRs of potential RoLR event providing only general details

If there is media speculation, ESC RoLR Contact Officer advises

CEO and Communications Manager

of the media interest

ESC RoLR Contact Officer informs CEO, Commissioners, DPI and Minister’s advisor (use RoLR

event briefing document at Attachment 8B)

ESC RoLR Contact Officer and Communications Manager to prepare newspaper ad and media

release (at Attachment 5).

ESC RoLR Contact Officer checks that the ESC is ready for

the RoLR event

ESC RoLR Contact Officer briefs CEO, Commissioners,

the Communications Manager, DPI and Minister’s advisor

ESC RoLR Contact Officer notifies

distributors and RoLRs that suspension was

not approved

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Diagram 2: Customer transfer process after RoLR was invoked

Purpose of this diagram is to show the ESC’s and AEMO’s procedure for transferring customers from the failed retailer to the RoLRs.

AEMO/RoLRs notify ESC RoLR Contact Officer that customer transfers have

been completed

RoLR Invoked

AEMO: 1) stops transfers to failed retailer 2) accelerates transfers away from failed retailer and 3) transfers other customers to RoLR

RoLRs confirm with ESC RoLR Contact Officer that customer

transfers have been completed

ESC RoLR Contact Officer to resolve problems with

AEMO/RoLRs

RoLRs notifies ESC RoLR Contact Officer that RoLR customer transfers have not been completed and

explains why

AEMO confirms with ESC RoLR Contact Officer that RoLR customer transfers

have been completed

AEMO notifies ESC RoLR Contact Officer that RoLR customer

transfers have not been completed and explains why

ESC RoLR Contact Officer briefs CEO,

Commissioners, DPI and Minister’s advisor

In accordance with Standing Request for Information agreed with AEMO: Electricity RoLR event – AEMO shall provide ESC RoLR Contact Officer with NMI and aggregated load profiles of retailer to be suspended Gas RoLR event – AEMO provides ESC RoLR Contact Officer with MIRNs and profiles of retailer to be deregistered

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Diagram 2A(1): Distributors’ process for transferring customers’ data after an electricity retailer has been suspended

Purpose of this diagram is to show the distributors’ role in the customer transfer process for a retailer failure in the electricity industry.

Distributor receives MSATS notification from AEMO of RoLR customer transfers and cancelled

customer transfers

Distributors receive formal notification from ESC RoLR Contact Officer that

RoLR has been invoked

Distributor confirm customer database has been updated

with RoLR customers

If failed retailer does not respond to RoLR, distributor (as data custodian) transfers relevant

information to the RoLR (using the customer information template in attachment 11)

Distributor notify ESC RoLR Contact Officer that data has been provided to the RoLR

Distributor allocate network bills to correct retailers

Distributor to ensure meter estimates received have been carried out in accordance with the

NEM Metrology Procedure

Distributor transfers metering

data to MSATS

Distributor transfers metering data to the failed retailer, the RoLR and, for transfers away

from the failed retailer that was accelerated, retailers of choice

RoLR Invoked

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Diagram 2A(2): Distributors’ process for transferring customers’ data after a gas retailer has been suspended

Purpose of this diagram is to show the distributors’ role in the customer transfer process for a retailer failure in the gas industry.

Distributors: 1) generate meter reads for transfer of RoLR customers 2) provide MIRNs and meter reads to RoLRs and failed retailer, and retailers of choice for transfers away from the railed retailer that was accelerated when the retailer failed

Distributors receive formal notification from ESC RoLR Contact Officer that

RoLR has been invoked

Distributors notify ESC RoLR Contact Officer that data has been provided to all relevant parties

RoLR Invoked

Distributors receive from AEMO notice of customer transfers and cancelled

customer transfers

Distributors confirm customer database has been updated with

RoLR customers

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Diagram 2B: Failed retailer’s process for transferring customers’ data upon suspension

Purpose of this diagram is to show the processes the failed retailer is likely to follow when it is suspended from purchasing electricity and/or gas in the wholesale market.

Retailer (the failed retailer) receives suspension notice from AEMO

Failed retailer reminded by the ESC of its obligations

under EI and GI Acts

Failed retailer decides whether or not to transfer customer data to RoLR

In accordance with EI and GI Acts, failed retailer requested by RoLR to

provide customer data

Failed retailer requests estimated meter reads from distributors

Distributors provide estimated meter reads

Failed retailer prepares final bills for customers

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Diagram 2C: RoLRs process for receiving the failed retailer’s customers’ data

Purpose of this diagram is to show how the failed retailer’s customers’ data, including metering data, will be transferred to the RoLRs.

RoLRs notified by ESC that a retailer failure has occurred

RoLR receives from AEMO (gas data custodian) and

distributors (electricity data custodian) details & profiles of

RoLR customers because failed retailer would not supply

the information

RoLR receives notification from AEMO of RoLR customer transfers

Validate RoLR customer data

RoLR receives metering data

RoLR updates customer database

RoLR to notify ESC that customer transfers

are successful

RoLR to notify ESC if there is a problem

Failed retailer responds to RoLR request under EI and GI Acts to

supply customer information

RoLR Invoked

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Diagram 3: Information flow from the ESC to RoLR following retailer suspension

Purpose of this diagram is to show when the ESC will communicate with the RoLRs about a retailer failure and the types of information that the ESC will send to the RoLRs.

ESC RoLR Contact Officer telephones RoLRs and provides general details of a

potential event

AEMO informs ESC that retailer has been issued with a

default notice

ESC RoLR Contact Officer telephones RoLRs and provides specific details of the event

AEMO informs ESC of decision to suspend retailer

ESC RoLR Contact Officer sends to RoLRs: 1) written advice about specific details of the event (see Template 1 in Attachment 6) 2) ESC’s letter to RoLR customers to be sent by the RoLR (see Template 2

in Attachment 6)

Towards end of RoLRs’ obligations, ESC RoLR Contact Officer provides RoLRs with ESC notice (Template 4 of Attachment 6) that will accompany the first bill to

customers

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Diagram 3A: Information flow from RoLRs to the ESC following retailer suspension

Purpose of this diagram is to show when the RoLRs should communicate with the ESC.

RoLRs are formally advised by the ESC of the specific details of the RoLR event

RoLRs send a copy of their letter and the ESC agreed letter to RoLR customers

The RoLRs’ letter is at Template 3 in Attachment 6. The ESC’s agreed letter is at Template 2 in Attachment 6.

RoLRs confirm that both letters have been mailed

RoLRs notify ESC RoLR customer data transfers have been completed

Before RoLR obligations expire, RoLRs to notify ESC that RoLR customers have been transferred to other retailers, to the RoLR’s market contract

or the RoLR’s default contracts

29

Diagram 4: Information flow between the ESC and distributors following retailer suspension

Purpose of this diagram is to show when the flow of information between the ESC and the distributors prior to and after the retailer is suspended from purchasing electricity and/or gas in the wholesale market.

ESC RoLR Contact Officer telephones distributors and provides general details of a

potential RoLR event

ESC RoLR Contact Officer telephones distributors and provides specific details

of the RoLR event

ESC RoLR Contact Officer sends to distributors, written advice about specific details of the RoLR

event (see Template 5 in Attachment 6)

ESC notifies distributors basic information on NMIs and supply addresses should be

provided to the RoLRs

Distributors confirm with ESC that basic information on NMIs and

supply addresses has been provided to the RoLRs

Distributors notify ESC that estimated meter reads will be

provided to the RoLRs for billing RoLR customers

Distributors confirm with ESC that estimated meter reads has been provided to the RoLRs for billing

RoLR customers

If failed retailer does not provide the data, data custodian has to step in. For electricity, distributors are the data custodian.

AEMO informs ESC that retailer has been issued with a

default notice

AEMO informs ESC of decision to suspend retailer

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Diagram 5: ESC process for communicating with call centre

Purpose of this diagram is to show the ESC’s processes for communicating with its call centre about the retailer failure.

ESC to maintain regular contact with call centre during the RoLRs 3 month period

ESC provides written advice (use Template 6 in Attachment 6) to its call centre of RoLR event, attaching Q&As

(from Attachment 7)

ESC to modify Q&As for call centre if initial Q&As

are inadequate

ESC to attend call centre in person to provide further

briefing if necessary

ESC to determine with call centre whether they need more information

ESC to provide call centre with more information if required

RoLR Invoked

ESC to send modified Q&As to call centre

31

Diagram 6: ESC process for communicating with Energy and Water Ombudsman, Victoria (EWOV)

Purpose of this diagram is to show the ESC’s processes for communicating with EWOV about the retailer failure.

ESC to maintain regular contact with EWOV

ESC RoLR Contact Officer provides EWOV with written advice (use Template 7 in Attachment 6), attaching:

1) Q&As (Attachment 7) and 2) ESC RoLR briefing document at attachment 8A or 8B

RoLR Invoked

ESC RoLR Contact Officer telephones EWOV and provides specific details of RoLR event

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Diagram 7: ESC process of monitoring RoLRs performance

Purpose of this diagram is to show the ESC’s processes for monitoring the RoLRs’ performance during its three months RoLR obligation period.

At end of 3 months:

RoLRs inform ESC that RoLR customers transferred to market

contracts or standing offers

Check RoLR duties are being carried out by:

ESC writes to RoLR about systemic problems

ESC meets with its call centre on regular basis to discuss enquiries / complaints received

In regular meetings with EWOV, discuss RoLR

related enquiries / complaints

In agreement with ESC, RoLR to report on RoLR related

enquiries / complaints received at their call centres

RoLRs confirm measures are in place to rectify enquiries / complaints and systemic problems

ESC conducts review of RoLR event and RoLRs performance

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Attachment 1 – RoLR Order in Council

34

Attachment 2 – Contact list

Commission

Position Contact Person Contact Details

RoLR Contact Officer Martin Johnson, Manager Compliance (Retail)

(03) 9032 1355

Back-up RoLR Contact Officer

Jeff Cefai, Director Energy (03) 9032 1320

Communications Manager

Amanda Clark (03) 9032 1324

Australian Energy Market Operator

Industry Contact Person Contact Details

Electricity and gas

Primary contact

Violette Mouchaileh, Group Manager, Retail Markets & Metering

(03) 9609 8551 or 0419 991 448 or [email protected]

Secondary contact

Chin Chan, Group Manager, Settlements and Prudentials

(03) 9609 8345 or 0408 976 306 or [email protected]

Back-up contact

Ruth Guest, Manager, Clearing and Prudential

(02) 8884 5312 or [email protected]

Relevant Government Departments

Department Contact Person Contact Details

Department of Primary Industries

Peter Clements 0411 157 564 or (03) 9658 4927

Australian Energy Regulator

Michelle Groves, CEO (03) 9290 1423

Ministerial office

Minister Contact Person Contact Details

Hon. Nicholas Kotsiras, Minister for Energy & Resources

Andrew Dillon, Senior Adviser – Energy

(03) 9658 4653

Distributor

Distributor Contact Person Contact Details

Jemena

Primary contact

Erin Chain, National Manager Stakeholder Relations

0404 822 339 or (03) 8873 7401 [email protected]

Back-ups

Robert Fornieri,

0409 532 935 or (03) 8873 7419

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Retail/Commercial Relationship Manager

[email protected]

United Energy, Multinet

Primary contact

Peter Georgiadis

Back-ups

Nichole Chaplin

Verity Watson




CitiPower and Powercor

Primary contact

Brent Cleeve

(03) 9683 4465 [email protected]

Alternate contact

David Turnour

0419 343 599 or (03) 9297 6080 or [email protected]

Envestra Errol Murray (08) 8113 9134

SP Ausnet

Primary contact

Elizabeth Colvin

0400 830 791 or [email protected]

Alternate contact

Darren Ferdinands

0419 751 090 or [email protected]

RoLR

Retailer Contact Person Contact Details

AGL

Beth Griggs, Head of Energy Market Regulation

(03) 8633 6077 or 0421 618 153

Nicole Wallis, Manager Retail Markets Regulation

(03) 8633 7440 or 0402 060 643

EnergyAustralia Lana Stockman, General Manager Retail Regulation and Compliance

(03) 8628 1632 or 0401 054 968

Origin Energy

Steve Clinch, Energy Relationships Manager

0407 354 745 or (03) 9652 5962

Malcolm Hempel, Industry Relationships Manager

0407 719 554 or (03) 9652 5984

Call centre

Call centre Contact Person Contact Details

Information Victoria Teena Hussey 9603 9932

EWOV

Job title Contact Person Contact Details

Operations Manager Cynthia Gebert (03) 8672 4254

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Attachment 3 – ESC AEMO RoLR communication protocol for the electricity industry

Australian Energy Market Operator Limited

ABN 94 072 010 327

Retailer of Last Resort (“ROLR”)

Protocol for communication between the Australian Energy Market Operator Ltd (“AEMO”) and the Essential Services Commission (“ESC”) regarding a potential ROLR event in the electricity market

Prepared by:

Version No: 4.0

Date: 22.12.2009

RoLR Operational Protocol: AEMO – ESC Victoria

38

1. Introduction

1.1 Purpose of this protocol

The ROLR Standing Instructions and the Standing Request for Information for First Tier and Second Tier Prudential Events (Attachments 1 and 2) are fundamental elements of the ROLR arrangements for Victoria. This protocol describes how AEMO and ESC intend to interact at a procedural level, to give effect to these instruments.

For the purposes of this protocol a ROLR will take responsibility for the supply of electricity to another retailer’s customers when that retailer’s right to acquire electricity from the National Electricity Market (“NEM”) is suspended or terminated.

The management of the ROLR arrangements in Victoria is the responsibility of the ESC. The ESC, as the jurisdictional regulator, is also responsible for any retail licence revocations in Victoria that will initiate ROLR. Such ROLR initiation is currently outside the scope of this protocol.

The execution of the National Electricity Rules (“Rules”) prudential process and execution of transfers from the failed retailer to the ROLR (ROLR Transfer) in the Metering, Settlement and Transfer Solution (“MSATS”) are the responsibilities of AEMO.

Hence there is a need for close co-ordination between the ESC and AEMO in the event or potential event of a ROLR.

This protocol specifies minimum communication requirements that aim to achieve that close co-ordination.

For a variety of reasons it may not be possible for communications between AEMO and the ESC to conform strictly to this protocol as actual events unfold.

For this reason, ESC and AEMO agree that this protocol is non-binding, although each party will use their best endeavours to comply with this protocol at all times.

However, the non-binding nature of this communication protocol does not remove the binding nature of the Standing Request for Information and the Standing Instruction referred to in this protocol.


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1.2 Outline of potential communication between AEMO and ESC

Figure 1 describes the basic interactions between AEMO and the ESC for the purposes of ROLR.

Figure 1. Potential ROLR triggers and AEMO/ESC communication

2 The need for ROLR arrangements

AEMO is responsible for the financial settlements associated with wholesale electricity trade in the NEM in accordance with the National Electricity Rules (Rules).

A critical aspect of this is the Prudential Supervision Process, which aims to minimise the spot market credit risk for sellers of wholesale electricity in the NEM, so that such sellers are not required to factor in a spot market credit risk premium in the offers that they make in the NEM.5

To ensure this, AEMO is required to establish and operate a process whereby a Market Participant purchasing electricity or market ancillary services from the spot market is required to maintain a specified level of credit support. This level of credit support is determined in accordance with the Rules in order to minimise the risk that

5 The Australian Energy Market Operator’s Prudential Supervision Process can be obtained at

http://www.aemo.com.au/electricityops/sett_prud_intro.html#process

NEM default event occurs

AEMO may suspend retailer

Standing/special request for information from ESC requires information from AEMO at each stage of prudential response.

Suspension and Standing ESC ROLR Instruction trigger ROLR transfer initiated by AEMO under the Standing Instructions un under the Standing ROLR

In absence of ESC ROLR Instructions customers of defaulting retailer may be disconnected on basis of a court order procured by the Australian Energy Regulator (“AER”)

Standing ROLR instruction from ESC requires AEMO to apply Victorian ROLR arrangements.

http://www.aemo.com.au/electricityops/sett_prud_intro.html#process


40

a Market Participant undergoing financial difficulties will exit the Market leaving debts that could not be recovered, by calling upon the credit support instruments provided to AEMO.

The Prudential Supervision Process requires AEMO to use an escalating process to seek rectification of a default by a market participant, including the issue of a call notice, default notice and ultimately potentially a suspension notice. In the event of suspension, and if no other action is taken, customers of the defaulting retailer could ultimately face disconnection of their electricity supplies.

The Rules allow disconnection to be avoided if the relevant NEM Jurisdiction has put in place a ROLR scheme under which customers of a defaulting retailer can be transferred to a ROLR6.

A jurisdictional ROLR scheme would put in place arrangements to nominate a retailer, to which customers of a defaulting retailer would be transferred and a mechanism for that nominated retailer to recover the associated costs.

3 The ROLR arrangements in Victoria

The ESC has an obligation under the Electricity Industry Act 2000 to manage the electricity industry ROLR arrangements for Victoria.

The ESC has made the following decisions in connection with electricity ROLR services for Victorian electricity customers that are relevant to AEMO’s market processes7:

Where a non-local retailer failure initiates a ROLR event, the customers of the failed non-local electricity retailer will be allocated to the Local Retailer for the area where the customer is located.

Where a Local Retailer failure initiates a ROLR event, the customers of the failed Local Retailer will be allocated to the remaining Local Retailers on a transmission node (TNI) basis. The schedule of the failed retailer’s TNIs and the corresponding remaining Local Retailers that the TNIs will be allocated to as the ROLR is set out in Attachment 1.

Following a ROLR event, customer transfers from the failed retailer to the ROLR may proceed on the basis of estimated meter readings.

Any change requests entered into MSATS that have not completed for customer transfers to the failed retailer must be cancelled so that the customer will remain with its existing retailer.

Requests for transfers away from the failed retailer that are already in MSATS, but have not yet been processed, must be accelerated to the new retailer using an estimated read as at the date the RoLR event is declared. Accelerated transfers away from the failed retailer apply only to in-situ transfer of customers consuming less than 160 MWh of electricity per annum. Accelerated transfers are limited by a maximum 65 day period, include all Change Request Statuses and apply to all change reason codes except retrospective and those relating to new move-ins.

6 Although ROLR is referred to in the singular in this Protocol, ROLR can refer to more than one retailer.

7 For these decisions see, Essential Services Commission, Energy Retailer of Last Resort – Final

Decision, February 2006. Note that in addition to the transfer related ROLR arrangements the ESC has made decisions about; customer price, customer retail contracts, provision of information to the ROLR, gas ROLR and customer and industry communications so that there is an overall approach to managing a ROLR event.


41

Customer transfers that do not relate to the ROLR are not impacted by a ROLR event.

4 Principles relating to ROLR event communications

AEMO and the ESC agree that the following principles will be applied to underpin communications during potential ROLR events:

a) During a potential ROLR event all formal communication between AEMO and the ESC will be channelled, where possible, through a single point of contact for each organisation referred to as the ROLR Contact Officer whose contact details are set out in Attachment 3.

b) The ROLR Contact Officer is duly authorised to make and receive any

communication required under this protocol.

c) ESC will specify what information it requires from AEMO for effective operation of the Victorian ROLR scheme in a formal Standing Request for Information. The Standing Request for Information will:

i) attach the appropriate powers of the ESC whereby release of this information by AEMO falls within the exemptions in Rules clause 8.6.2 as acceptable grounds under which information can be released to third parties; and

ii) detail the extent of the information and the stage of the prudential supervision process at which the information is to be provided;

d) Subject to clause e) AEMO will provide the information specified in the Standing Request for Information directly to ESC provided doing so would be consistent with AEMO’s confidentiality obligations under the Rules. ESC will make arrangements for distribution of the information to the ROLR where ESC deems such distribution as essential for effective operation of the Victorian ROLR process;

e) AEMO will provide to ESC only that information to which it has access through its normal settlement and metering processes. If there is other information that ESC deems as necessary for the ROLR function then the ESC will obtain this information from other sources by means outside of this protocol;

f) AEMO will not communicate with the ROLR regarding a prudential incident until an announcement of the Suspension has been made; and

g) AEMO will only initiate a ROLR Transfer in MSATS if an instruction is provided by the ESC on behalf of the jurisdiction under the Rules.8

h) If circumstances should arise where the ESC believed additional information is required or some information is required at a point earlier than specified in the Standing Request for Information, then the ESC must issue to AEMO a formal Special Request for Information listing the additional requirements. This request will be in a similar format to the Standing Request for Information in that it will:

i) Confirm that the Request for Information is in accordance with the appropriate powers of ESC so that release of this information falls within the exemptions set down in the Rules Clause 8.6.2 as acceptable

8 National Electricity Rules section 3.15.21.(j)


42

grounds under which confidential information can be released to third parties; and

ii) Detail the extent of the additional information and the stage in the prudential supervision process at which this information is required to be released.

i) AEMO may seek amendments to a Standing Request for Information or Special Request for Information from the ESC if it is not satisfied that this request meets the requirements set out above or if the intent of the Request can be otherwise met more efficiently.

j) Where AEMO receives information from or on behalf of a retailer that the retailer requests a suspension from the National Electricity Market AEMO will use its reasonable endeavours to verbally advise the RoLR contact officer of the ESC of the receipt of that information provided that such information is not confidential information as defined by the Rules and provided that AEMO is not prohibited to disclose such information otherwise.

5 ROLR Communication procedure

In the event that AEMO is required to transfer information to the ESC in accordance with the Standing Request for Information, or to initiate the ROLR process in MSATS in accordance with the Standing Instruction from ESC, interaction between AEMO and ESC will need to be effective and efficient. Accordingly, a ROLR communication procedure has been agreed for use between AEMO and ESC in such cases. 5.1 General ROLR communication principles The ROLR Communication Procedure is as follows:

a) All formal communication between AEMO and the ESC to meet the requirements of the Standing Request for Information and the Standing ROLR Instruction will be conducted, where possible, only between nominated ROLR Contact Officers in AEMO and the ESC;

b) Where AEMO is required to provide information to the ESC under the Standing Request for Information:

i) The AEMO ROLR Contact Officer is to initially make verbal contact with the ESC ROLR contact officer and advise that information is about to be transferred in accordance with this protocol, and confirm readiness to receive the information;

ii) The AEMO ROLR Contact Officer will then transfer the information by email;

iii) The ESC ROLR Contact Officer will acknowledge receipt of the information by return email.

5.2 ROLR initiation and communication of initiation AEMO will initiate ROLR and communicate with the ESC about the initiation as follows:


43

a) AEMO, subject to being satisfied that a valid Instruction or Standing Instruction to transfer customers to a ROLR is in place for a relevant retailer, will use its best endeavours to carry out the ROLR Transfer in MSATS as set out in the instruction as soon as practicable and in accordance with MSATS CATS Procedures, noting that it is not necessary to fulfil (b) in order to implement the ROLR transfer.

b) In the event that AEMO suspends a retailer for which there is a ROLR Standing Instruction from ESC, it will communicate with the ESC as follows:

i) The AEMO ROLR Contact Officer will make verbal contact with the ESC ROLR Contact Officer to advise that a ROLR initiation advice is about to be sent to ESC;

ii) AEMO emails a ROLR initiation advice to the ESC ROLR Contact Officer indicating the approximate time that it will initiate the ROLR Transfer. This advice will include confirmation of the total number of customers to be transferred, and estimated program for the transfer;

iii) The ESC ROLR Contact Officer will acknowledge receipt of the ROLR initiation advice by return email;

iv) AEMO will further advise ESC when the ROLR Transfers have been initiated in MSATS;

v) AEMO will carry out the ROLR Transfer in MSATS; and

vi) AEMO will transmit a ROLR transfer confirmation advice by email to the ESC ROLR contact officer once the ROLR Transfer has been completed, indicating whether the customer transfers were successful.

6 Nomination of ROLR Contact Officers

AEMO and the ESC will each nominate a ROLR Contact Officer who will conduct all formal prudential or ROLR communications between the organisations (see attachment 3). Any notification of changes to the ROLR Contact List in Attachment 3 will be amended by AEMO and an updated version of Attachment 3 will be sent to the ESC. Changes to Attachment 3 resulting from a change of contact details will not constitute a need to formally update this Protocol.

7 Method of Communication

Initial communication between the ROLR Contact Officers will be verbal, to ensure availability of the relevant persons, and to ensure efficiency of communication. Verbal messages will subsequently be confirmed in writing by email transmission of a duly authorised document (usually a signed attachment to an email). Such email messages will be marked as urgent, and sent to the email addresses nominated in the ROLR Contact List. Any data required to be provided by AEMO will also be transmitted by e-mail to the e-mail address nominated for the appropriate ESC ROLR Contact Officer in the ROLR Contact List. In the event that e-mail is not available or suitable for any written communication and confirmation under this protocol, the parties may agree on any other method to communicate written information or data under this protocol (i.e. fax).


44

ROLR Contact Officers within AEMO and ESC will then be responsible for disseminating this information appropriately within their own organisations.

8 Management of This Protocol

If either party believes at any time that this protocol should be amended, then that party will make a formal request to the other party for an amendment to the protocol. This protocol will then only be amended by mutual agreement. The parties will act in good faith to mutually agree any amendment to this protocol. This protocol will be updated with all relevant contact details and reviewed jointly by AEMO and the ESC:

a) Following any prudential or ROLR event that has required use of this protocol; or

b) Annually if no prudential or ROLR event has occurred;

An exercise will be conducted to test the continuing effectiveness of this protocol bi-annually. This exercise will be managed by AEMO. Each party will bear their own costs in relation to this exercise. A report to ESC on the outcomes of the exercise will be prepared by AEMO. This report will include recommendations for improvements to this protocol or related processes where deemed necessary.

RoLR Operational Protocol: AEMO – ESC Victoria Attachment 1: AEMO Standing Instructions and Request for Information – First Tier Prudential Event

45


46


47

RoLR Operational Protocol: AEMO – ESC Victoria Attachment 2: AEMO Standing Instructions and Request for Information – Second Tier Prudential Event

48


49


50


51


52


53

54

Attachment 3 – ROLR Contact Officer List The following list indicates the ROLR Contact Officers for ESC and AEMO at the time this protocol was agreed between the parties. The list is subject to change as described in section 6 of this protocol.

AEMO ROLR Contact Officer

Name: Violette Mouchaileh Title: Group Manager, Retail Markets & Metering Phone: (03) 9609 8551 Mobile: 0419 991 448 Fax: (03) 9609 8080

Email: [email protected]

Address: GPO Box 2008 Melbourne VIC 3001 (street address provided only if need arises)

AEMO backup ROLR Contact Officer

Name: Chin Chan Title: Group Manager, Settlements and Prudentials Phone: (03) 9609 8345 Mobile: 0408 976 306 Fax: (03) 9609 8080 Email: [email protected]


ESC ROLR Contact Officer

Name: Martin Johnson Title: Manager, Compliance (Retail) Phone: 03 9032 1355 Mobile: Fax: 03 9032 1303 Email: [email protected] Address: Level 37, 2 Lonsdale St Melbourne, Victoria 3000

ESC backup ROLR Contact Officer

Name: Jeff Cefai Title: Director Energy Phone: 03 9032 1320 Mobile: 0422 235 411 Fax: 03 9032 1303 Email: [email protected] Address: Level 37, 2 Lonsdale St Melbourne, Victoria 3000

mailto:[email protected]

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Attachment 4 – ESC AEMO RoLR communication protocol for the gas industry

Retailer of Last Resort (“RoLR”)

Protocol for communication between the Australian Energy Market Operator (“AEMO”) and the Essential Services Commission (“ESC”) regarding a potential RoLR event in the gas industry

56

1 Introduction

1.1 Purpose of this protocol

The RoLR Standing Direction and Standing Request for Information (Appendix 1) are fundamental elements of the RoLR arrangements.

This protocol describes how AEMO and the ESC intend to interact at a procedural level, to give effect to these instruments and to ensure both the ESC and AEMO are informed and able to respond to a RoLR event in the appropriate timeframes.

For the purposes of this protocol a RoLR will take responsibility for the supply of energy to another retailer’s customers when AEMO has revoked the Market Participant’s registration.

The management of the RoLR arrangements in Victoria is the responsibility of the ESC. The ESC, as the jurisdictional regulator, is also responsible for any retail licence revocations in Victoria that will initiate RoLR. Such RoLR initiation is outside the scope of this protocol.

The operation of the National Gas Rules (“NGR”) prudential process and execution of transfers from the failed retailer to the RoLR (RoLR Transfer) in the metering and settlement systems are the responsibilities of AEMO.

Hence there is a need for close co-ordination between the ESC and AEMO in the event or potential event of a RoLR.

This protocol specifies minimum communication requirements that aim to achieve that close co-ordination.

For a variety of reasons it may not be possible for communications between AEMO and the ESC to conform strictly to this protocol as actual events unfold.

For this reason, the ESC and AEMO agree that this protocol is non-binding, although each party will use their best endeavours to comply with this protocol at all times.

However, the non-binding nature of this communication protocol does not remove the binding nature of the Standing Direction and the Standing Request for Information referred to in this protocol.

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1.2 Outline of communication steps between AEMO and ESC

Figure 1 describes the basic interactions between AEMO and the ESC for the purposes of RoLR.

Figure 1. Potential RoLR triggers and AEMO/ESC communication

2 The need for RoLR arrangements

AEMO is responsible for the financial settlements associated with wholesale gas in the Victorian gas market managed under the NGR.

AEMO is required under the NGR to establish and operate a prudential management process (see Appendix 2) whereby a Market Participant operating in the spot market is required to maintain its financial exposure in the spot market to within specified limits based on the level of credit support it provides to AEMO. The objective of these requirements is to minimise the risk that a Market Participant undergoing financial difficulties will exit the Market leaving debts that could not be recovered by calling upon the credit support instruments provided to AEMO.

The NGR prudential management process requires AEMO to use an escalating process to ensure the credit support provided by each Market Participant is adequate to cover its market exposure at any time. The process includes the issue of warning notices, a margin call notice and a suspension notice, which ultimately results in the revocation of a

NGR default event occurs (initial suspension or margin calls not met)

AEMO may suspend retailer registration in accordance with the NGR

Notice sent from AEMO to the ESC providing information specified in a standing formal request for information relating to a prudential default, and at each subsequent stage of AEMO’s prudential response.

RoLR transfers are triggered by AEMO in accordance with the ESC RoLR Standing Direction

In absence of the ESC RoLR Instructions customers of defaulting retailer may be disconnected

Suspension Notice sent from AEMO to the ESC

Standing Direction from the ESC requires AEMO to apply Victorian RoLR arrangements.

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market participant’s registration if the market participant fails to resolve its prudential situation by the date specified in the Suspension notice.

If a retailer’s registration as a Market Participant is revoked by the Suspension Notice under the NGR then, for its customers to continue to be able to withdraw gas, another retailer is required to assume responsibility for the gas supply to those customers.

Under the Gas Industry Act 2001 (GIA), deregistration of a Market Participant in the category of Retailer is a trigger for a RoLR event, upon which AEMO can be required to follow directions issued by the ESC to effect the transfer of customers from the deregistered retailer to a RoLR9.

3 The RoLR arrangements

The ESC has an obligation under the GIA to manage the energy industry RoLR arrangements for Victoria.

The ESC has made the following decisions in connection with gas RoLR services for Victorian gas customers that are relevant to AEMO’s market processes10:

Where a non-local retailer failure initiates a RoLR event, the customers of the failed non-local retailer will be allocated to the declared Host Retailer (as per the NGR) for the distribution area where the customer is located.11

Where a Local Retailer failure initiates a RoLR event, the customers of the failed Local Retailer will be allocated to the remaining Local Retailer for the distribution area.

Following a RoLR event, customer transfers from the failed retailer to the RoLR may proceed on the basis of estimated meter readings.

Requests that have been initiated in the AEMO customer transfer system (CATS) but have not completed for customer transfers:

to the failed retailer, must be cancelled so that the customer will remain with its existing retailer

away from the failed retailer, must be allowed to proceed using an estimated read as at the date of the RoLR event is declared.

Customer transfers that do not relate to the failed retailer or the RoLR are not impacted by a RoLR event.

The ESC’s decisions referred to above use the concept of a Local Retailer. The equivalent concept in the NGR is the Host Retailer.

4 Principles relating to RoLR event communications

AEMO and the ESC agree that the following principles will be applied to underpin communications during potential or developing RoLR events:

k) During a potential or developing RoLR event all formal communication between AEMO and the ESC will be channelled, where possible, through a single point of

9 Although a RoLR is referred to in the singular in this Protocol, RoLR can refer to more than one retailer.

10 For these decisions see, Essential Services Commission, Energy Retailer of Last Resort – Final Decision, February 2006, and the Draft Decision: Amendments To Energy Retail Code & Electricity Customer Transfer Code – Retailer Of Last Resort & Assignment To Third Party. Note that in addition to the transfer related RoLR arrangements the ESC has made decisions about; customer price, customer retail contracts, provision of information to the RoLR, gas RoLR and customer and industry communications so that there is an overall approach to managing a RoLR event. 11

Refer to the Commission’s final decision, Geographic boundaries for gas retailers of last resort, September

2008.

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contact for each organisation referred to as the RoLR Contact Officer whose contact details are set out in Appendix 3.

l) The RoLR Contact Officer is duly authorised to make and receive any

communication required under this protocol.

m) ESC will specify what information it requires from AEMO for effective operation of the Victorian RoLR scheme in a formal Standing Request for Information. The Standing Request for Information will:

i) attach the appropriate powers of the ESC whereby release of this information by AEMO falls within the exceptions under rule 138A(5) of the NGR as acceptable grounds under which confidential information can be released to third parties; and

ii) detail the extent of the information and the stage of the prudential supervision process at which the information is to be provided;

n) Subject to clause e) AEMO will provide the information specified in the Standing Request for Information directly to the ESC provided doing so would be consistent with AEMO’s confidentiality obligations under the NGR and the Retail Market Procedures (Victoria). The ESC will make arrangements for distribution of the information to the RoLR where the ESC deems such distribution as essential for effective operation of the Victorian RoLR process;

o) AEMO will provide to the ESC only that information to which it has access through its normal settlement and metering processes. If there is other information that the ESC deems as necessary for the RoLR function then the ESC will obtain this information from other sources by means outside of this protocol;

p) AEMO will not communicate with the RoLR regarding a prudential incident until an announcement of the RoLR trigger event has been made; and

q) AEMO will only initiate a RoLR Transfer in the metering and settlement systems if an instruction is provided by the ESC under the GIA.

r) If circumstances should arise where the ESC believed additional information is required or some information is required at a point earlier than specified in the Standing Request for Information, then the ESC must issue to AEMO a formal Special Request for Information listing the additional requirements. This request will be in a similar format to the Standing Request for Information in that it will:

i) Confirm that the Request for Information is in accordance with the appropriate powers of the ESC so that release of this information falls within the exceptions set down under rule 138A(5) of the NGR as acceptable grounds under which confidential information can be released to third parties; and

ii) Detail the extent of the additional information and the stage in the prudential supervision process at which this information is required to be released.

s) AEMO may seek amendments to a Standing Request for Information or Special Request for Information from the ESC if it is not satisfied that this request meets the requirements set out above or if the intent of the Request can be otherwise met more efficiently.

t) Where AEMO receives information from or on behalf of a retailer that the retailer requests a suspension from the Victorian gas market managed under the NGR, AEMO will use its reasonable endeavours to verbally advise the RoLR contact officer of the ESC of the receipt of that information provided that such information is not confidential information as defined by the NGR and provided that AEMO is not otherwise prohibited to disclose such information.

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5 RoLR Communication procedure

In the event that AEMO is required to transfer information to the ESC in accordance with the Standing Request for Information, or to initiate the RoLR processes in the metering and settlement systems, interaction between AEMO and the ESC will need to be effective and efficient. Accordingly, the following agreed RoLR communication procedure is to be used between AEMO and the ESC in such cases. 5.1 General RoLR communication principles The RoLR Communication Procedure is as follows:

c) All formal communication between AEMO and the ESC to meet the requirements of the Standing Direction and the Standing Request for Information will be conducted, where possible, only between nominated RoLR Contact Officers in AEMO and the ESC;

d) Where AEMO is required to provide information to the ESC under the Standing Request for Information regarding the issue of a margin call or notify the satisfactory response to a margin call:

i) The AEMO RoLR Contact Officer will transfer the information by email;

ii) The ESC RoLR Contact Officer will acknowledge receipt of the information by return email.

e) Where AEMO is required to provide information to the ESC under the Standing Request for Information other than as set out in 5.1(b):

i) The AEMO RoLR Contact Officer is initially to make verbal contact with the ESC RoLR contact officer and advise that information is about to be transferred in accordance with this protocol, and confirm readiness to receive the information;

ii) The AEMO RoLR Contact Officer will then transfer the information by email;

iii) The ESC RoLR Contact Officer will acknowledge receipt of the information by return email.

5.2 RoLR initiation and communication of initiation On the initiation of a RoLR event AEMO will communicate with the ESC about the initiation as follows:

a) AEMO, subject to being satisfied that a Participant’s registration has been effectively revoked, will use its best endeavours to carry out the RoLR transfer in the metering and settlement systems as soon as practicable, noting that it is not necessary to fulfil (b) in order to implement the RoLR transfer.

b) In the event that AEMO suspends a retailer for which there is a RoLR standing direction from the ESC, it will communicate with the ESC as follows:

i) The AEMO RoLR Contact Officer will make verbal contact with the ESC RoLR Contact Officer to advise that a “RoLR initiation advice” is about to be sent to the ESC;

ii) AEMO emails a “RoLR initiation advice” to the ESC RoLR Contact Officer indicating the approximate date and time that it intends to revoke the Participant’s registration and initiate the RoLR Transfer. This advice will include confirmation of the total number of customers impacted, and the time estimated to complete the program for transfer;

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iii) The ESC RoLR Contact Officer will acknowledge receipt of the “RoLR initiation advice” by return email;

iv) AEMO will further advise the ESC when RoLR Transfers have been initiated in the metering and settlement systems;

v) AEMO will carry out the RoLR Transfer in the metering and settlement systems; and

vi) AEMO will transmit a RoLR transfer confirmation advice by email to the ESC RoLR contact officer once the RoLR Transfer has been completed, indicating whether the customer transfers were successful.

6 Nomination of RoLR Contact Officers

AEMO and the ESC will each nominate a RoLR Contact Officer who will conduct all formal prudential or RoLR communications between the organisations. The identity of the contact officers and any nominated deputies, and their contact details (telephone numbers, facsimile numbers, e-mail addresses and street addresses), will be specified in a RoLR Contact List maintained by AEMO. AEMO will amend the RoLR Contact List promptly when advised of any change to the details of nominated contact persons and forward the revised contact list electronically to a distribution list provided by the ESC as revised from time to time.

7 Method of Communication

Other than for routine notifications regarding the issuing of margin calls or the satisfactory response to margin calls, where email communications will be used, all initial communications between the RoLR Contact Officers will be verbal, to ensure availability of the relevant persons, and to ensure efficiency of communication. Verbal messages will subsequently be confirmed in writing by email transmission of a duly authorised document (usually a signed attachment to an email). Such email messages will be marked as urgent, and sent to the email addresses nominated in the RoLR Contact List and/or different persons nominated as a result of the initial verbal interaction. Any data required to be provided by AEMO will also be transmitted by e-mail to the e-mail address nominated for the appropriate ESC RoLR Contact Officer in the RoLR Contact List and copied to the backup Contact Officer. In the event that e-mail is not available or suitable for any written communication and confirmation under this protocol, the parties may agree on any other method to communicate written information or data under this protocol (i.e. fax). RoLR Contact Officers within AEMO and the ESC will then be responsible for disseminating this information appropriately within their own organisations.

8 Management of This Protocol

If either party believes at any time that this protocol should be amended, then that party will make a formal request to the other party for an amendment to the protocol. This protocol will then only be amended by mutual agreement. The parties will act in good faith to mutually agree any amendment to this protocol. This protocol will be updated with all relevant contact details and reviewed jointly by AEMO and the ESC:

c) Following any prudential or RoLR event that has required use of this protocol; or

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d) Annually if no prudential or RoLR event has occurred;

An exercise will be conducted to test the continuing effectiveness of this protocol bi-annually. This exercise will be managed by AEMO. Each party will bear their own costs in relation to this exercise. A report to the ESC on the outcomes of the exercise will be prepared by AEMO. This report will include recommendations for improvements to this protocol or related processes where deemed necessary.

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Appendix 1: Standing Direction and Standing Request for Information

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Appendix 2: Prudential Supervision Process

Event AEMO action Notice issues

Participant reaches 80% of the trading limit

AEMO issues warning notice to Participant

No communication required with the ESC

Participant reaches or exceeds the trading limit

AEMO issues a Margin call requiring updated security by:

2pm on the day if issued before 10am; or

10am on next business day if issued after 10am.

1. Advice provided to the ESC, via e-mail, notifying the fact that a margin call has been issued 2. Advice provided to the ESC, via e-mail, whether the Margin Call has been met or not

Participant fails to meet the margin call

AEMO issues a suspension notice after Participant fails to meet the margin call

Advice provided to the ESC, initially by phone, then follow-up e-mail, notifying the fact that a suspension notice has been issued and advising the ESC of the projected deregistration date assigned to the suspension notice.

Participant remedies the prudential position

AEMO revokes suspension notice

Advice provided to the ESC, initially by phone, then follow-up e-mail, notifying the fact that a suspension notice has been revoked.

Participant fails to remedy their prudential position

AEMO revokes the Participant’s registration and initiates RoLR processes

Advice provided to the ESC, initially by phone, then follow-up e-mail, notifying the fact that a participant’s registration has been revoked.

ESC provides a notice to AEMO confirming the fact that a RoLR event has been initiated.

AEMO initiates RoLR processes

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Appendix 3 – RoLR Contact Officer List The following list indicates the RoLR Contact Officers for the ESC and AEMO at the time this protocol was agreed between the parties. The list is subject to change as described in section 6 of this protocol.

AEMO ROLR Contact Officer

Name: Violette Mouchaileh Title: Group Manager, Retail Markets & Metering Phone: (03) 9609 8551 Mobile: 0419 991 448 Fax: (03) 9609 8080

Email: [email protected]


AEMO backup ROLR Contact Officer

Name: Chin Chan Title: Group Manager, Settlements and Prudentials Phone: (03) 9609 8345 Mobile: 0408 976 306 Fax: (03) 9609 8080 Email: [email protected]


ESC ROLR Contact Officer

Name: Martin Johnson Title: Manager, Compliance (Retail) Phone: 03 9032 1355 Mobile: Fax: 03 9032 1303 Email: [email protected] Address: Level 37, 2 Lonsdale St Melbourne, Victoria 3000

ESC backup ROLR Contact Officer

Name: Jeff Cefai Title: Director Energy Phone: 03 9032 1320 Mobile: 0422 235 411 Fax: 03 9032 1303 Email: [email protected] Address: Level 37, 2 Lonsdale St Melbourne, Victoria 3000

mailto:[email protected]

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Attachment 5 – RoLR media template

NEWSPAPER AD

Notice to former customers of [failed retailer]

Transfer of retail energy accounts

The Essential Services Commission, Victoria’s independent economic regulator

responsible for the licensing of energy retailers, has advised that on [XX Month

Year], Victorian customers of [failed retailer] were transferred to another electricity

retailer. This follows the market suspension of [failed retailer] on the same day.

Former customers of [failed retailer] will not experience an interruption of electricity

supply in the transfer to the new retailer and there will be no change to the quality,

safety or reliability of their energy supply resulting from the transfer. However, prices

may change with a new retailer and customers may have to pay a one-off

administration fee.

The Essential Services Commission will continue to closely monitor energy retailers

to ensure all customers are assured of the highest quality and reliability of energy

supply at competitive prices.

Your new retailer – either Origin Energy, AGL or EnergyAustralia, depending on

your customer address - will be writing to you shortly, setting out your options.

If you have any questions, please call the Essential Services Commission’s call centre

on 1300 134 545 or visit our website at www.esc.vic.gov.au

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Sample Media Release

MEDIA RELEASE

No XX/2010 (TRIM number)

XX Month Year

FORMER [FAILED RETAILER’S] CUSTOMERS TRANSFERRED TO NEW

ENERGY RETAILERS

Former Victorian electricity customers of [failed retailer] have been transferred to three

new electricity retailers after [failed retailer] was suspended from participating in the

National Energy Market on [XXXday, XX Month].

The former [failed retailer’s] customers in Victoria will be transferred to Origin

Energy, AGL or EnergyAustralia, depending on the customer address, under the

Essential Services Commission’s Retailer of Last Resort procedures.

If an energy retailer fails, the Commission has the powers provided by licence

conditions made under the Gas Industry Act 2001 and Electricity Industry Act 2000 to

protect customers by facilitating their transfer to a new retailer.

[Failed retailer] was suspended [because…]. In Victoria, [failed retailer has around

XXX domestic customers].

Origin Energy, AGL and EnergyAustralia will be writing to former [failed retailer’s]

customers shortly to explain the Commission’s approved terms of their supply and to

ensure that customers receive full information and advice. The arrangements ensure

that [failed retailer’s] customers will continue to receive uninterrupted electricity

supply.

However, prices may change with a new retailer and customers may have to pay a one-

off administration fee.

If a customer wishes to then enter into a contract with another retailer, they should

contact that retailer, which will provide the information they need and arrange the

transfer. The Essential Services Commission can provide information on choosing a

new retailer and a list of alternative retailers.

The Essential Services Commission can be contacted on 1300 134 545. Alternatively

customers can visit www.esc.vic.gov.au

For further information contact:

Amanda Clark (03) 9032 1324 or 0411 117 297

http://www.esc.vic.gov.au/

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Attachment 6 – Letter and notification templates

Template 1 – ESC formal notification to RoLRs of Retailer of Last Resort event

{XX Month 2010)

RoLR’s address block

Dear {Name of RoLR representative}

Retailer of last resort event of {XX Month 2010}

As you will be aware, on {XX Month 2010} the energy retailer {name of retailer} was suspended

by the Australian Energy Market Operator (AEMO) {explain reasons}. This triggered a retailer

of last resort event for {retailer’s} {XXX customers} in Victoria.

Although the Essential Services Commission is doing its best to advise {retailer’s} customers of

how they are affected and how they might respond, some customers may be somewhat

confused, and potentially annoyed, about an involuntary change in their energy retailer.

I would like to thank {RoLR} for its cooperation to date following this retailer of last resort event. I

would ask that you continue to make every effort to assist the customers who have been

transferred to {RoLR} as a result of this event.

Yours sincerely

Dr Ron Ben-David Chairperson

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Template 2 – ESC letter to RoLR customers (on ESC letterhead)

{XX Month 2010}

C/09/35818

FORMER {Retailer’s name} CUSTOMERS TRANSFERRED TO NEW ENERGY RETAILERS

On {XXXday, XX Month} your energy retailer, {Retailer’s name} was suspended from

participating in the National Energy Market {explain reason}. As a result, {Retailer}can no longer

sell you electricity.

In these circumstances, Victorian law provides for you to be transferred automatically to one of the

three major retailers - AGL, Origin Energy or EnergyAustralia. One of these three companies has

already been assigned as your retailer to ensure your energy supply continues uninterrupted.

Your retailer of last resort is now required to sell you electricity for three months at tariffs, terms and conditions approved by the Essential Services Commission, Victoria’s independent economic regulator. This may include a payment of up to {$65 revise amount if necessary} as a one off administration fee, which covers costs incurred by that retailer to sell you electricity.

Your options now are:

do nothing, and after three months you will be transferred onto the standing contract of the

retailer of last resort. A standing contract does not have a fixed term;

ask your retailer of last resort if they can provide you with a better offer (sometimes called a

market contract); or

obtain quotes from competing retailers and transfer to another retailer with a competitive offer.

You can find a list of competing retailers on the Your Choice website

(www.YourChoice.vic.gov.au).

Please be assured that despite the transfer of your retail electricity account, the continuity and

reliability of your electricity supply should not be affected.

Queries can be directed to the Essential Services Commission on 1300 134 575 or to your retailer

of last resort.

Yours sincerely

Dr Ron Ben-David CHAIRPERSON

http://www.yourchoice.vic.gov.au/

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Template 3 – RoLRs letter to customers (on RoLRs’ letterhead and as agreed with the ESC)

NAME ADDRESS 1 ADDRESS 2

Dear XXXX

On {date}, your energy retailer, {Failed retailer}, was suspended from the energy market because of {reason}. Consequently, {Failed retailer} can no longer supply you with electricity and/or gas.

Under such circumstances, Victorian law requires you to be automatically transferred to a retailer of last resort, in order to ensure your energy supply continues. In your area, we, {ROLR}, are the retailer of last resort.

As your retailer of last resort, we will now supply you with electricity and/or gas for a period of up to 3 months to {date the ROLR period ceases} at tariffs and on terms and conditions that have been approved by the Essential Services Commission. This includes payment of a one off supply fee, which covers costs incurred by us to sell you electricity and/or gas.

Your options now are:

obtain quotes from competing retailers and transfer to another retailer with a better offer; or

ask us about our range of electricity and gas contracts you can move on to; or

do nothing, and after three months you will be transferred onto a standing offer at government regulated tariffs, terms and conditions. A standing contract has no fixed term.

Please be assured that despite this event, the continuity and reliability of your electricity and/or gas supply should not be affected.

If you have any queries please either contact us on {xxxx} or the Essential Services Commission’s call centre on 1300 134 575.

Yours sincerely

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Template 4 – ESC letter to customers to be sent with the RoLRs’ first bills

NOT UPDATED YET

On {date} {Failed retailer} was suspended from the energy market because of {reason}. Consequently, you have been supplied with electricity and/or gas from your retailer of last resort, {RoLR}.

In this bill, you may notice that you have been charged for your consumption of energy at a different rate. This is because {RoLR} is selling you energy at a retailer of last resort tariff rate that has been approved by the Essential Services Commission, Victoria’s independent economic regulator. You have also been charged an up front, one off retailer of last resort supply fee. This fee has been charged by the retailer of last resort to cover costs incurred by them to sell you energy.

If you have any queries in relation to this bill, please contact {RoLR} on {RoLR’s phone number}. Alternatively, you can contact the Essential Services Commission on 1300 134 575.

Template 5 – ESC formal notification to distributors of RoLR event

(See C/09/35782)

{Date and time}

This serves to notify {distributor’s name} that the Australian Energy Market Operator Limited (AEMO) has issued a suspension notice to {failed retailer’s name} at {specify time and date}, under clause 3.15.21(f) of the National Electricity Rules (Rules).

{Failed retailer} was a second tier retailer.

{Failed retailer} has {specify number} customers in Victoria on the date of market suspension.

As a result of the market suspension of {failed retailer}, the Retailer of Last Resort (RoLR) event has been invoked effective midnight on {specify date}.

The relevant ROLRs are:

AGL Sales Pty Ltd

Origin Energy Pty Ltd

EnergyAustralia Pty Ltd

Please enact your relevant RoLR arrangements in accordance with the procedures.

Yours sincerely

Martin Johnson Manager, Compliance (Retail)

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Template 6 – ESC notification to call centre of RoLR event

(See C/09/35787)

I advise that {Failed retailer} was suspended from the market effective midnight on {specify date}.

{Failed retailer} had approximately {specify number} customers in Victoria on the date of market suspension.

As a result of the market suspension of {Failed retailer}, the Retailer of Last Resort (RoLR) event was invoked on {specify date}. Customers have been successfully transferred to the RoLRs by the market operator. However, most of these customers will not know what has happened until they either receive a notification from {Failed retailer}or their new retailer (the RoLR).

The RoLRs in Victoria are AGL, Origin Energy and EnergyAustralia. We do not yet know which customers have been transferred to which retailer.

{Attach Q&As, organise briefing meeting}

Template 7 – ESC notification to EWOV of RoLR event

(See C/09/35788)

Further to my telephone calls, I advise that the Australian Energy Market Operator Limited (AEMO) has issued a suspension notice to {Failed retailer} at {specify time and date}, under clause 3.15.21(f) of the National Electricity Rules (Rules).

{Failed retailer} had approximately {specify number} customers in Victoria on the date of market suspension.

As a result of the market suspension of {Failed retailer}, the Retailer of Last Resort (RoLR) event was invoked effective midnight on {specify date}. Customers have been successfully transferred to the RoLRs by the market operator, but it is not known at this time how many customers have gone to which retailer.

The relevant RoLRs are AGL, Origin Energy and EnergyAustralia.

{Attach Q&As}

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Attachment 7 – RoLR questions & answers

(From C/09/35784) a) What is the name of the failed energy retailer?

The retailer is called {specify name}. It serviced customers in {specify state/s} and has about {specify number} customers in Victoria.

b) How did this happen?

In order to supply customers with electricity or gas, energy retailers have to purchase their energy from the wholesale market and the distribution businesses. If an energy retailer does not have sufficient funds to pay for its present and future wholesale and distributed energy, the wholesale market operator will suspend the retailer from the market. This is what happened to {failed retailer}. If this happens, customers are transferred to the retailers of last resort designated by the Essential Services Commission.

c) What was the reason for the retailer’s failure?

{Specify reasons} For example, Jackgreen could not pay its distribution bills in NSW. The distributor, Integral Energy, took it to the NSW Supreme Court on 8 December. On 18 December, when they went back to Court, Jackgreen went into voluntary administration.

d) Who will this affect?

The only customers affected will be those whose retailer is {failed retailer}.

e) What will happen to the customers?

The Government has put a scheme in place called the Retailer of Last Resort Scheme, which means that if a retailer fails all customers are transferred to a retailer of last resort and they do not lose continuity of supply. These retailers are AGL, EnergyAustralia and Origin Energy

f) What does Retailer of Last Resort mean?

It refers to the Retailer in your area who is designated to provide you with electricity in this kind of event

g) Will electricity/gas supplies be cut off?

No customer is cut off from supply when a retailer fails. As the customer, you are not required to do anything or contact anyone in order to ensure your supply is not cut off. Your new retailer (your retailer of last resort) will be in touch with you very shortly.

h) I was a customer of Jackgreen, but have not been contacted yet by anyone.

If the customer’s call is less than 2 weeks from the date of the RoLR event, advise the caller that new retailers known as Retailers of Last Resort (ROLRs) are endeavouring to contact everyone as soon as possible. You should call back to this number if you have not heard from your new retailer after 2 weeks.

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If the customer’s call is more than 2 weeks from the date of the RoLR event, ask the caller for the address of the property which was receiving the electricity then advise the caller to contact retailer of last resort in their area (refer to map supplied).

i) What will happen next?

Your new supplier will contact you within the next couple of weeks. The letter will explain a number of things including:

The date that the new arrangements took place

The Terms and conditions of your electricity supplier

That you can change to another electricity retailer.

j) Will there be a cost to Victorian taxpayers as a result of a retailer of last resort event being invoked?

No, no taxpayers’ money is used for retailer of last resort arrangements. Customers are simply transferred from one retailer to another.

k) How long has the ESC known that a retailer of last resort event was likely?

Victorian law (the Electricity Industry Act and Gas Industry Act) require that a retailer of last resort event be called as soon as the electricity or gas market operator (the Australian Energy Market Operator) suspends a retailer from the market. The ESC plays no role in market suspension and monitors all participants’ adherence to their responsibilities under the retailer of last resort scheme as soon as it learns of market suspension of a retailer. Market suspension was effective {specify time and date} and the ESC advised everyone concerned on {specify date}.

l) I had just signed a contract with {failed retailer}. What does the failure of {failed retailer} mean?

This depends on whether your transfer has been formally processed through the market operator’s systems. If your transfer has not been processed, your transfer to {failed retailer}will be stopped and you will stay with your previous retailer. If your transfer has already been processed, you will be transferred to a Retailer of Last Resort in accordance with Victorian law. You are free to change to another contract with any retailer at anytime. If you have been transferred to a ROLR you should receive a letter from them over the next 2 weeks. If you are not contacted by a ROLR, you may wish to contact your previous retailer to clarify it still has you registered as a customer.

m) My previous retailer was {failed retailer}, but I have just signed a new contract with a different retailer — what will happen?

If your transfer is in the system, your transfer will be accelerated to the new retailer you chose. Contact the retailer you recently signed with and ask what is happening.

n) My previous retailer was {failed retailer}, but I have just signed a new contract with a different retailer, but I have received a notice on behalf of the (RoLR) indicating that they have taken over my electricity service. What do I do?

It is possible because of the timing of events that you may have received a RoLR notice by mistake. You should contact your {RoLR} to explain that you had signed a contract.

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o) I was disputing my last bill with the {failed retailer} and they said they would look at it.

What will happen now?

You should contact {failed retailer} as they or their administrator may have in place interim processes for handling unresolved customer complaints. If customer says that {failed retailer} is not answering their calls, transfer the call to {nominate ESC contact person and number}.

p) I was paying {failed retailer}by direct debit. Will my direct debit automatically cease?

{failed retailer} or their Administrators have an obligation under the Energy Retail Code (see clause 7.2(b)) to immediately cancel the direct debit arrangement and notify both you and the financial institution of the cancellation. You may wish to contact your financial institution to confirm that the direct debit arrangement with {failed retailer} has been cancelled.

q) I have received a letter from [RoLR] informing me that {failed retailer} has been

suspended from the market and I have been transferred to [RoLR]. The retailer has also informed me that I will now be paying an amount for my electricity that is much higher than what I was charged by {failed retailer}.

Please transfer call to {nominate ESC contact person and number}

r) How long will it take me to transfer from the RoLR arrangements?

You are free to transfer anytime from your RoLR arrangements and the transfer should happen at the same speed as any other transfer. You should discuss with the retailer you intend to contract with when it would arrange a meter read to start billing you.

s) I have received a bill from (RoLR) but I never gave consent to be a customer of that retailer.

If you were a customer of {failed retailer} you should have received a letter from {RoLR} informing you that {failed retailer} has failed and you were therefore transferred to [RoLR] who is the retailer of last resort in your area. A retailer of last resort is required under Victorian law (Electricity Industry Act & Gas Industry Act) in order to protect you from being disconnected as a result of the failure of a retailer. Your consent was not required in order for you to be transferred to the retailer of last resort. The [RoLR] can charge you the standing offer tariff that has been published by them and on the YourChoice website. This applies to customers who are transferred to [RoLR] due to the failure of {failed retailer}. The tariffs have been set with fairness to both the customer and the RoLR in mind. They may also charge a one-off fee of $65. Your options now are:

obtain quotes from competing retailers and transfer to another retailer with a competitive offer

ask for a description of the retailer of last resort’s market contracts, which may feature a lower tariff

Do nothing, and after three months your relationship with the {RoLR} will change. You will be charged under RoLR tariffs, but another set of prices that that retailer is entitled under legislation to charge users who have not signed a contract with {RoLR}. The {RoLR} will be able to advise the difference in charge if any between this charge and the RoLR tariff. You should contact them if you require more information.

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t) I have received a bill from [RoLR], but it covers an incorrect billing period or I have

received a bill from [RoLR] and my old/new retailer and their billing periods overlap.

Check that the start date of the {RoLR’s} bill starts on the date the retailer of last resort event was invoked. If not then advise to contact the RoLR and query the bill. Check that the end date of the bill from {failed retailer} coincides with the date on which RoLR was invoked. If the end date on the {failed retailer’s} bill passes the date on which RoLR was invoked, refer the call to Compliance Manager or ESC RoLR Contact Officer. If there is overlap between dates of a RoLR bill and a further retailer bill (i.e. not of {failed retailer}) advise them to contact either of these retailers to address the double billing issue.

u) I have refused to pay my bill to [RoLR] because I never agreed to pay those tariffs.

Now retailer has threatened to disconnect me. What can I do?

[RoLR] is charging you the standing offer tariff that they are allowed to charge you as the RoLR. This tariff applies to customers who are transferred to [RoLR] due to the failure of Jackgreen. You are obligated to pay this tariff for any energy that [RoLR] has already sold to you. The tariffs have been set with fairness to both the customer and the RoLR in mind. Please be aware that before you can be disconnected for non-payment of a bill, the retailer must comply with obligations under the Energy Retail Code which include sending a reminder notice and disconnection warning. Your Retailer of Last Resort cannot disconnect you immediately, without first complying with these obligations under the Energy Retail Code.

v) Can I make a complaint about my bill from {failed retailer}?

Yes. You can contact the Energy and Water Ombudsman of Victoria (EWOV) on 1800 500 509

Can I make a complaint about my bill from my Retailer of last Resort?

Contact your RoLR to discuss any issues you may be experiencing.

w) [RoLR] has charged my a retailer of last resort supply fee? Can they do this?

Retailer of last resort supply fees have been approved by the ESC. The purpose of the supply fee is to cover cost incurred by the retailer of last resort to sell you electricity and/or gas. Retailer of last resort supply fee - $65 The retailer of last resort supply fee is a one off fee which is an amount the regulator has decided the RoLR can elect to pass on in full or in part having considered:

the RoLR’s administrative costs, and

The risks and costs associated with taking over Jackgreen’s responsibility for the purchase of electricity and gas from the wholesale market on short notice.

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Attachment 8A – ESC RoLR briefing document for an electricity RoLR event

The ESC/staff wish/es to inform you that AEMO’s Prudential Committee has issued a Suspension Notice to [retailer name], which states that [retailer name] is suspended from trading in the NEM as of [time and date]. The suspension was triggered by a series of events which began on [date] when AEMO advised [retailer name] in a Call Notice that its [Outstandings exceeded its Trading Limit]. [Retailer name’s] failure to adequately respond to the Call Notice prompted AEMO to issue a Default Notice requiring [retailer name] to rectify its prudential position by [date]. AEMO issued the Suspension Notice after [retailer name] failed to meet the requirements specified in the Default Notice. Below are some key statistics regarding [retailer name] for your information

Ownership

Who is the parent company………………………………………………………………….

Operations

Years of operations in Victoria……………………………………………………………….

States in which it has a licence to sell to small customers……………………………….

States in which it actively services small customers……………………………………….

Market share in Victoria……………………………………………………………………….

Customer numbers in Victoria (residential/business).…………………………………….

Market share in Australia……………………………………………………………………..

Customer numbers in Australia (residential/business)…………………………………….

Products

Electricity……………………………………………………………………………………….

Dual Fuel……………………………………………………………………………………….

Other relevant Information

……………………………..…………………………………………………………………….

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Attachment 8B – ESC RoLR briefing document for a gas RoLR event

The ESC/staff wish/es to inform you that AEMO has issued a Suspension Notice to [retailer name], which states that [retailer name] is suspended from trading in the Victorian gas market as of [time and date]. The suspension was triggered by a series of events which began on [date] [when AEMO advised] [retailer name] [in a Margin Call notice that it had reached/exceeded its trading limit] or [when AEMO advised] [retailer name] [in a Default Notice that it has not paid money owing or provided the required level of credit support]. [Retailer name’s] failure to adequately respond to the [Margin Call / Default Notice] prompted AEMO to issue a Suspension Notice to [retailer name] requiring it to rectify its prudential position by [date]. As it failed to do so, AEMO has revoked the registration of [retailer name] as a market participant. Below are some key statistics regarding [retailer name] for your information

Ownership

Who is the parent company………………………………………………………………….

Operations

Years of operations in Victoria……………………………………………………………….

States in which it has a licence to sell to small customers……………………………….

States in which it actively services small customers……………………………………….

Market share in Victoria……………………………………………………………………….

Customer numbers in Victoria (residential/business).…………………………………….

Market share in Australia……………………………………………………………………..

Customer numbers in Australia (residential/business)…………………………………….

Products

Gas…….……………………………………………………………………………………….

Dual Fuel……………………………………………………………………………………….

Other relevant Information

……………………………………………………………………………………………………

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Attachment 9 – ESC, EWOV and RoLR protocol for handling customer queries/complaints during a Retailer of Last Resort event

The following document provides guidance on how customer queries/complaints are handled during a Retailer of Last Resort (RoLR) event.

Queries/complaints regarding the RoLR scheme

Queries/complaints regarding the RoLR scheme should be directed to the RoLR or the Essential Services Commission (Commission) for response. These types of queries/complaints may refer to:

RoLR tariff, terms and conditions (including RoLR supply fee).

Customer transfer

Automatic transfer

Lack of choice.

Privacy, where the customer is unhappy that their personal information has been transferred to the RoLR without consent.

Transfer cancellations.

The type of meter read used to enable the transfer.

The operation of the RoLR scheme. In determining whether the query or complaint should be handled by the RoLR or Commission, there should be regard to whether the issue relates to the policy/regulation of the scheme or the customer’s supply arrangements with the RoLR.

Queries/complaints involving the failed retailer

There will be two types of queries/complaints which will be directed to the failed retailer:

Non-RoLR customer issues which were unresolved or not finalised when the retailer failed.

Issues that emerged due to the RoLR event. Non-RoLR customer issues that were unresolved or not finalised when the retailer failed may include, but are not limited to:

Billing, hardship, wrongful disconnection, marketing, retail competition & transfer.

Cases that have been referred to a higher level (RHL) with the failed retailer prior to their failure. In these cases, the customer may ring the Energy and Water Ombudsman (Victoria) (EWOV) back because they are not satisfied with the outcome or because they have heard that the retailer has failed and the customer is seeking expedient resolution.

Credit listing issues where the failed retailer had listed the customer with a credit reporting agency and the customer disputes the accuracy of the report and seeks removal of listing from their credit record.

Queries/complaints that emerged due to the RoLR event may include, but are not limited to:

Loss of loyalty reward, where the customer was about to get a rebate or other reward but this is ‘lost’ because the retailer fails.

Terms of payment of arrears owed to failed retailer.

Failure to honour agreements achieved from internal and the EWOV conciliated resolutions.

Final bill from failed retailer.

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Wrongful disconnection before the RoLR event.

Direct debit, where full account arrears are unexpectedly deducted in one transaction or ongoing payments have been deducted in error

Service orders not being completed (ie transfers, special meter reads, meter checks etc).

Refund of payment for services to be undertaken by a Distributor who subsequently cancels the service request upon a RoLR event.

Refunds of payments made in advance, or credits on accounts. These queries should be referred to the failed retailer for resolution. If the issue remains unresolved, the customer should be advised of their right to access dispute resolution services from EWOV. Questions relating to the cancellation of direct debit or Centrepay arrangements can be referred to the failed retailer. The customer may also contact their financial institution if it is a direct debit arrangement or Centrelink, if it is a Centrepay arrangement.

Queries/complaints involving the RoLR

Queries/complaints relating to the customer’s consumption of and payment for energy from the RoLR, should be directed to the RoLR in the first instance. These types of queries/complaints may refer to, but are not limited to:

An old debt being chased by the RoLR.

Concession not applied to first bill of the RoLR.

Customer was on a hardship program with the failed retailer, but finds themselves subject to normal collection processes with the RoLR.

Requested time to pay the bill involving the RoLR supply fee.

Bill formatting, for example, incorrect name on bill. These queries should be referred to the RoLR for resolution. If the issue remains unresolved, the customer should be advised of their right to access dispute resolution services from EWOV.

Unclear

Queries/complaints may arise during a RoLR event where it is unclear who it should be referred to for resolution. For example, if a failed retailer has not processed a customer disconnection/connection request at the time of their suspension from the market, which party will ensure it is progressed? In these cases, it is recommended that the following principle be applied:

If the issue refers to an event raised with the retailer before they failed, it should

be referred to the failed retailer in the first instance. If the event has occurred after

the retailer failed, it should be referred to the RoLR in the first instance

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Attachment 10 – Approved RoLR tariff terms and conditions

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Attachment 11 – Customer information template for data custodians

CUSTOMER DATA PROVIDED BY RETAILERS TO DATA CUSTODIAN

Electricity Gas

Customer’s name Customers name

Business name (for business customers) Business name (for business customers)

Contact name (for business customers) Contact name (for business customers)

Primary contact number Primary contact number

Secondary contact number Secondary contact number

NMI MIRN

NMI Checksum MIRN Checksum

Address for services of notices (as provided to distributor under clause 9.4 of Default Use Of System Agreement)

Billing address

Supply address

Medical practitioners confirmation if supply is not to be interrupted

Medical practitioners confirmation if supply is not to be interrupted

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Attachment 12 – ESC checklist for a RoLR event

essential services commission€¦ · victoria would provide the rolr service for all the customers...

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