QLD STTM PROJECT:
STTM RULE CHANGE PROPOSAL –
CONSULTATION PAPER
PREPARED BY:
AEMO
VEN DOCS #:
321941
VERSION:
1
DATE:
10 February 2011
STATUS:
FINAL
QLD STTM PROJECT
STTM RULE CHANGE PROPOSAL – CONSULTATION PAPER
Contents
1
Introduction ...................................................................................................... 3
2
About AEMO .................................................................................................... 3
3
Consultation Process ....................................................................................... 4
4
Matters for Consultation ................................................................................... 5
5
Inquiries ........................................................................................................... 5
6
Submissions ..................................................................................................... 5
6.1
Lodging a submission................................................................................................. 5
6.2
Form and content of submissions ............................................................................... 6
6.3
AEMO’s consideration of submissions........................................................................ 7
List of Abbreviations and Symbols
ABBREVIATION
TERM
AEMC
Australian Energy Market Commission
AEMO
Australian Energy Market Operator
AER
Australian Energy Regulator
MCE
Ministerial Council on Energy
NGL
National Gas Law
NGR
National Gas Rules
STTM
Short Term Trading Market
STTM-CF
STTM Consultative Forum
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QLD STTM PROJECT
STTM RULE CHANGE PROPOSAL – CONSULTATION PAPER
1 Introduction
Early in 2010 the Ministerial Council on Energy (MCE) and the Queensland Government
announced that the Short Term Trading Market (STTM) was to be implemented in Queensland in
2011. The MCE asked the Australian Energy Market Operator (AEMO) to implement the STTM,
initially at a new hub at Brisbane, by December 2011; with the potential for further hubs in
Queensland in the future. To facilitate this policy, the MCE incorporated provisions into the STTM
Rules within the National Gas Rules (NGR) to provide for the establishment of a Brisbane hub.
The MCE noted that the establishment of the Brisbane hub was a significant development in the
Queensland gas market and will further progress the MCE’s gas market reform agenda. The
Queensland Government is committed to implementing the STTM at the Brisbane hub in 2011.
AEMO has undertaken a detailed review of the application of the STTM design to the Brisbane
hub, in light of the physical characteristics of the network and the bilateral contractual
arrangements that exist at Brisbane. The review was conducted in consultation with industry
through the STTM Consultative Forum (STTM-CF). The review verified that the STTM can be
applied to that hub without change to the core design of the STTM. The review identified the need
for changes to the transportation agreements and it is understood that negotiations on this have
started. The review also identified the need for minor Rule changes to address technical aspects
of the implementation, as follows:
1. Permitting self contracting users to participate in the Queensland retail gas market
2. Providing a different gas day for the Brisbane hub
3. Allowing all withdrawals from a hub to be treated equally
4. Permitting Transmission connected users to participate in contingency gas
5. Making technical amendments to the transitional provisions
AEMO is proposing to submit these Proposed Rule Changes to the Australian Energy Market
Commission (AEMC) for consideration under the “fast-track” rule change process.
This Consultation Paper has been prepared by AEMO to facilitate public consultation on the Rule
change proposals prior to submission. It provides:

A background to AEMO;

A summary of the intended process for progressing the STTM Rule Change Proposal

An overview of documentation presented for consultation; and

Contact details for inquiries;

Guidance as to how submissions should be made to AEMO
2 About AEMO
The Australian Energy Market Operator commenced operations on 1 July 2009.
AEMO was established by the Council of Australian Governments and developed under the
guidance of the Ministerial Council on Energy. The company operates on a cost recovery basis as
a corporate entity limited by guarantee under the Corporations Act.
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AEMO’s functions are:

Markets: AEMO manages both wholesale and retail markets in electricity and gas across
eastern and south-eastern Australia.

Operations: As a wholesale market operator, AEMO also oversees the vital system
operations and security of Australia’s National Electricity Market and Victorian gas
transmission network.

Planning: In its role as National Transmission Planner, AEMO delivers essential planning
advice and forecasting to guide long term investment in Australia’s energy network
infrastructure and resource management.

Development: AEMO works in consultation with industry and government to further develop
and improve Australia’s gas and electricity markets.
AEMO delivers an array of strategic and operational functions within the energy sector including:

Day-to-day management of wholesale and retail energy market operations, and emergency
protocols.

National transmission planning.

Ongoing market development.

Infrastructure management and planning.

Stakeholder consultation and facilitation.

Long-term market planning.
AEMO sits at the centre of energy market operations, and has a complementary role with the other
energy market institutions—the Australian Energy Regulator (AER)1 and the AEMC2. The market
institutions operate within a policy framework provided by the MCE.
Together with the AER and the AEMC, AEMO aims to strengthen the national character of energy
market governance, to increase efficiencies in the operation of gas and electricity markets, and to
create a truly national framework for infrastructure planning and development.
3 Consultation Process
This is the first formal stage of a multi-stage consultation process:
1
2

AEMO invites submissions on AEMO’s Draft Rule Change Proposal.

AEMO will review submissions, with each issue submitted being reported along with
AEMO’s response to the issue

AEMO incorporates relevant issues submitted into the Rule change proposal submission
that is lodged with the AEMC.

AEMO submits the Rule Change Proposal to the AEMC for consideration under the “fasttrack” rule change process (AEMO will request the AEMC to “fast track” the Rule change
procedure, which bypasses the first round consultation).

AEMC considers the Rule Change Proposal in accordance with the National Gas Law
(NGL).
National Energy Market Compliance Regulator
National Energy Market Rule Maker
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STTM RULE CHANGE PROPOSAL – CONSULTATION PAPER
4
Matters for Consultation
AEMO is seeking comment on the Draft Rule Change Proposal that it intends to submit to the
AEMC.
The papers that form the core elements of the Draft Rule Change Proposal are the following
Attachments3:
•
Attachment A: Draft Rule Change Proposal, which sets out matters that are pertinent to the
proposed changes to the Rules that govern the STTM (primarily Part 20)
•
Attachment B: Proposed Rules, which presents the proposed amendments to the Rules,
showing changes from Version 7 of the NGR
•
Attachment C: Overview of the STTM, which presents background information regarding
the establishment and operation of the STTM
AEMO is particularly interested in submissions that respond to questions raised in Attachment A:
Draft Rule Change Proposal, which also relate to Attachment B: Proposed Rules.
5
Inquiries
Inquiries related to this Consultation Paper should be directed to:
Contact name: Craig Price
Contact phone: 1300 858 724
E-mail address: [email protected]
6
Submissions
AEMO has published a Notice of Consultation that advises interested parties that it is consulting on
a Draft STTM Rule Change Proposal. AEMO now invites submissions on this draft Rule change
proposal.
The closing date for submissions is:
Friday 18 March 2011
6.1 Lodging a submission
Submissions on the Rule Change Proposal must be made in writing and submitted by email in both
PDF and Word format to [email protected]. The Subject header in the email should be “QLD
STTM Rule Change Proposal”.
PDF submissions on behalf of an organisation must be on company letterhead and signed and
dated.
Parties wishing to make submissions should note that, as this is a public consultation, all
submissions received by AEMO will be made available to the public by publication on its website.
3
AEMO will prepare an additional attachment that summarises the submissions received during this
consultation and addresses the matters raised. When complete, this Attachment, along with the other
Attachments, will be published when AEMO makes its application to the AEMC for the proposed rule
changes.
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Upon receipt of the submission, AEMO will issue a confirmation email. If this confirmation email is
not received within 3 business days, it is the submitter's responsibility to ensure the submission
has been successfully delivered.
6.2 Form and content of submissions
Submissions may or may not relate to specific questions. This section details what is required for
a submission to be considered by AEMO.
6.2.1 Responses to Questions
•
Question id – such as A3.1 or A6.2
•
Response – that could indicate support or otherwise. If the response is not supportive of
the Draft STTM Rule Change Proposal, a clear explanation of the issue and rationale is
required.
6.2.2 Responses that are generic
•
Attachment section – such as ‘A1’, ‘B2’, ‘C1’, ‘D3’, etc.
•
Subsection – such as 2.1, 4.5, etc.
or
Rule reference (rule and subrule) for comments on Attachment section B2
•
Extract of relevant content from the Draft STTM Rule Change Proposal
•
Comments that clearly indicate the issue with the Draft STTM Rule Change Proposal
•
Change marked version of the relevant content (optional)
6.2.3 Claim for confidentiality of information included in submissions
AEMO’s usual practice is to publish all submissions on its website. However, in certain
circumstances, those who make a submission may make a claim that it contains confidential
information. Such a claim should clearly identify the part or parts of the submission that the claim
for confidentiality relates to, and give reasons why AEMO should accept the claim that the material
be treated as confidential.
Where AEMO forms the view that the claim to confidentiality is justified, it may decide to publish
the submission, but omitting the confidential information. In such a case, AEMO will include a note
to the effect that confidential information has been omitted at each place in the submission where
this has occurred.
However, parties wishing to make a submission that contains confidential information should take
note that AEMO may not be able to address or include the matters in its application to the AEMC
for a Draft Rule Change Proposal, as that application is public.
6.2.4 Personal information disclosed in a submission
AEMO will not disclose certain personal information of individuals (such as personal (home)
addresses, telephone numbers) in written submissions that are posted on the AEMO website.
Those preparing submissions are requested to review the submission to ensure that no such
material has been inadvertently incorporated into the submission.
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6.2.5 What should be kept in mind when preparing a submission?
The following guidance, by way of a checklist of questions, may assist those preparing a
submission:
•
Does the submission reflect that the person making the submission has a correct
understanding about the nature, scope and context of the particular STTM Rule Change
Proposal?
•
Does the submission link comments and discussion to the issues raised by the Draft STTM
Rule Change Proposal?
•
Does the submission appropriately respond, given the stage of the Rule making decision
process? This is intended to be a de facto first round consultation, so submissions should
provide comment and views on the Draft STTM Rule Change Proposal.
6.3 AEMO’s consideration of submissions
Parties intending to make a submission should note the following requirements:
•
Timeliness:
AEMO will take into account submissions lodged within the timeframe as part of its
considerations. Where submissions are received by AEMO after the closing date, AEMO
will endeavour to have regard to these late submissions where it is reasonably able to do
so.
•
Relevance to the particular Rule change proposal:
Persons making a submission on the Draft STTM Rule Change Proposal should focus on
issues that are relevant to this proposal. While AEMO recognises there are overlapping
and interlinking issues, it is nevertheless important for stakeholders to ensure the relevance
of their submission to this proposal.
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