On 14 January 2010 Gas Industry Co published a notice in the New Zealand Gazette stating that it had approved critical contingency management plans covering the whole transmission system and announcing the go-live date, 21 January 2010, on which parts 3 and 4 of the regulations come into force. The text of this notice is available by clicking on the link below.
Extract from the New Zealand Gazette
The presentation below was developed by Gas Industry Co and the critical contingency operator to highlight the key responsibilities of industry participants and consumers under the new contingency management arrangements and to summarise the communication protocols between the parties affected by contingency events.
The Gas Governance (Critical Contingency Management) Regulations 2008 (the Regulations) were published in the New Zealand Gazette on 6 November 2008. Parts 1, 2 and 5 came into force on 4 December 2008 and parts 3 and 4 came into force on 21 January 2010 (the go-live date).
The purpose of the Regulations is to achieve the effective management of critical gas outages and other security of supply contingencies without compromising long-term security of supply. The Regulations provide for:
Part 1 covers general provisions for the appointment of the CCO and terms of the CCO service provider agreement, the scope of the Regulations, funding of the development and ongoing fees, and the giving and receiving of notices.
Part 2 covers the obligations of certain parties prior to the critical contingency management go-live date (Go-Live Date), in relation to CCMPs, the communications plan and information guide, and the provision of transmission system and consumer information.
Part 3 sets out the processes for the determination, declaration and termination of a critical contingency and the role and obligations of certain parties during a contingency event.
Part 4 provides for obligations after critical contingency events, including reporting requirements, and processes for the appointment of an industry expert, determination of a critical contingency price and the determination and resolution of contingency imbalances.
Part 5 provides for miscellaneous activities such as audits, the treatment of critical contingencies occurring before the Go-Live Date and the separation of roles for the CCO.
For each proposed CCMP or amendment to a CCMP, an expert adviser must be appointed by Gas Industry Co to review the proposed plan or amendment and to make a recommendation on whether Gas Industry Co should approve the proposed plan or amendment. Gas Industry Co must appoint an expert adviser within 30 business days of the commencement date in the case of a proposed plan and, for a proposed amendment, within 5 business days of receiving the amendment from the TSO.
On 27 January 2009, Gas Industry Co appointed Concept Consulting Group Limited as the Expert Adviser to review the initial critical contingency management plans proposed by Vector Gas Limited and Maui Development Limited respectively.
The terms and conditions of the appointment are available by clicking on the link below:
Expert Adviser appointment - 27 January 2009
Gas Industry Co must appoint an independent industry expert to determine the critical contingency price within 10 business days of the termination of a critical contingency. Each TSO, interconnected party, and shipper who will be affected by the determination of a critical contingency price may nominate 1 person to be considered by Gas Industry Co when appointing the industry expert.
The Contingency Management Regulations provide for the industry body (Gas Industry Co) to determine and publish certain matters regarding the operation of the regulations. Notice of these determinations is available by clicking on the link below:
Critical Contingency Management Determinations v1.0
Date Published: May/June 2008
Authors: Vector/Contact
A group was convened by Contact Energy, and its role was to work towards a better understanding of the interdependencies between the electricity and gas sectors. Membership of the group was broad, covering gas transmission, electricity generation, electricity system operation (Transpower), the Electricity Commission and Gas Industry Co. Both Vector and Contact Energy undertook modelling work which was presented to that group and the outputs from that work are provided below.
Vector gas modelling
Covering Letter
Contingency Modelling
Contact electricity modelling
Covering Letter
Contingency Modelling
The CCO (Vector Gas Limited) was appointed by Gas Industry Co on 28 November 2008.
This is in line with regulation 6 which requires Gas Industry Co to appoint the person that is the system operator of all of the transmission system as the CCO for an initial term of 5 years. Regulation 8 of the Contingency Management Regulations requires that Gas Industry Co publish the CCO service provider agreement. Accordingly, a copy of the service provider agreement is available by clicking on the link below.
Regulation 10(3) of the Gas Governance (Critical Contingency Management) Regulations 2008 requires that the industry body publish a map depicting the transmission system based on information supplied by transmission system owners under regulation 10(1).
The transmission system map, along with the accompanying pipeline schematics, is available to view or download from the publications section of the CCO's website which can be accessed by clicking on the link below.
Before submitting a critical contingency management plan (CCMP) for approval, transmission system owners (TSOs) are required to consult on a draft of the proposed plan with persons representative of the interests of those likely to be affected by the CCMP.
Immediately before this consultation, TSOs must provide a draft of the CCMP to the industry body to be published on their website.
Gas Industry Co has received draft CCMPs from Maui Development Ltd and Vector Gas Transmission, which are available to view or download by clicking on the links below. Please note that submissions on the draft plans should be made directly to the relevant TSO.
MDL Draft Critical Contingency Management Plan (submissions closed 10 February 2009)
Vector Draft Critical Contingency Management Plan (submissions closed 10 February 2009)
Proposed CCMPs were submitted to Gas Industry Co for approval in February 2009. The plans were reviewed by the expert adviser, who gave notice on 27 March 2009 that the plans should not be approved by Gas Industry Co. Following revisions in accordance with the expert adviser's notice, the TSOs resubmitted proposed CCMPs for approval on 15 April 2009. The resubmitted plans are available to view or download by clicking on the links belows.
On 18 May 2009 the expert adviser notified Gas Industry Co that the two amended plans had not been recommended for approval as they were incomplete. TSOs were therefore given 10 further business days to amend their proposed plans in line with the expert adviser's notice.
MDL resubmitted an amended proposed CCMP on 26 May 2009, and Vector submitted on 4th June. The plans can be accessed by clicking on the links below.
On 3 July 2009 the expert adviser wrote to Gas Industry Co to recommend that the proposed CCMP submitted by MDL on 26 May 2009 not be approved. MDL subsequently submitted an amended proposed CCMP which can be accessed by clicking on the link below.
On 14 July 2009 the expert adviser wrote to Gas Industry Co to recommend that the proposed CCMP submitted by Vector on 4 June 2009 not be approved. Vector subsequently submitted an amended proposed CCMP which can be accessed by clicking on the link below.
On 17 August 2009 the expert adviser wrote to Gas Industry Co to recommend that the proposed CCMP submitted by MDL on 17 July 2009 not be approved. MDL subsequently submitted an amended proposed CCMP which can be accessed by clicking on the link below.
On 23 October 2009 the expert adviser wrote to Gas Industry Co to recommend that the proposed CCMP submitted by Vector on 23 September 2009 not be approved. Vector subsequently resubmitted an updated proposed CCMP which can be accessed by clicking on the link below.
On 9 September 2009 Gas Industry Co received a recommendation from the expert adviser to approve MDL's proposed CCMP. After considering the plan, Gas Industry Co agreed that it complies with regulation 25 and gives effect to the purpose of the regulations and the CCMP was therefore approved on 16 September. The approved CCMP can be viewed by clicking on the link below. The regulations referred to as Attachment 1 can be found here
On 10 December 2009 Gas Industry Co received a recommendation from the expert adviser to approve Vector's CCMP. After considering the plan, Gas Industry Co agreed that it complies with regulation 25 and gives effect to the purpose of the regulations and the CCMP was therefore approved on 18 December 2009. The approved CCMP can be viewed by clicking on the link below.
These Guidelines are not required under the Regulations. Gas Industry Co intends to use the Guidelines as a means of ensuring a consistent approach to designations in respect of large consumers and in considering designation disputes from consumers generally. Although the Guidelines do not have any particular status under the Regulations, it is hoped that retailers will perceive value in the Guidelines when processing applications from their customers. In this way, classifications could be expected to be reasonably consistent across retailers. Please note these Guidelines are not legally binding and need to be read in conjunction with the Regulations. The general approach set out in these Guidelines in no way reduces the requirement upon participants to know and comply with their obligations under the Regulations.
Essential Services and Minimal Load Guidelines
Regulations 17 through 19 of the Contingency Management Regulations provide for ongoing fees to be paid by wholesale purchasers of gas on a monthly basis to meet the critical contingency ongoing costs. The critical contingency ongoing costs are the costs:
Gas Industry Co has determined that the critical contingency ongoing costs should exclude any overhead costs or policy work resulting from operational activities under the Contingency Management Regulations. Any such work is to be funded from the Gas Industry Co Levy. The critical contingency ongoing costs therefore only relate to other direct external costs in connection with Gas Industry Co administering the Contingency Management Regulations.
For each year following the first year or part year of operation, Gas Industry Co must estimate and publish a breakdown of the estimated critical contingency ongoing costs for that year. The breakdown is set out in the table below.
| Estimated ongoing costs of Contingency Management Regulations | |
|
Cost categories |
Estimated cost |
| Service provider (establishment and base fees) | $442,000 |
| Service provider (event fee) | $71,000 |
| Industry expert costs | $75,000 |
| Expert adviser costs | $5,000 |
| Total ongoing costs | $593,000 |
|
Invoice month |
for gas consumed in |
CC ongoing cost ($/GJ) |
| July 2010 | May 2010 | $0.0035627345 |
| August 2010 | June 2010 | $0.0033662262 |
| September 2010 | July 2010 | $0.0032837221 |
As soon as practicable after the go-live date, Gas Industry Co must determine and publish a breakdown of the estimated critical contingency ongoing costs for the first year or part year of operation of the critical contingency management plans. The breakdown is set out in the table below.
|
Estimated ongoing costs of Contingency Management Regulations |
|
| Cost categories |
Estimated cost (part year) |
| Service provider (establishment and base fees) | $196,666 |
| Service provider event fee | $71,000 |
| Expert adviser/Industry expert costs | $81,000 |
| External advisers | $30,000 |
| Total ongoing costs | $378,666 |
| Invoice month | for gas consumed in | CC ongoing cost ($/GJ) |
| February 2010 | December 2009 | $0.0062117452 |
| March 2010 | January 2010 | $0.0062540428 |
| April 2010 | February 2010 | $0.0062757035 |
| May 2010 | March 2010 | $0.0051482701 |
| June 2010 | April 2010 | $0.0056451463 |
The Contingency Management Regulations provide for Gas Industry Co to recover the critical contingency development costs (the development costs) from wholesale purchasers of gas, via a development fee.
The development costs are—
The development costs were incurred by Gas Industry Co between the commencement date (4 December 2008) and go-live date of the Regulations. Under regulation 16(3) Gas Industry Co is required to determine and publish a breakdown of the estimated development costs on its website. As soon as practicable after go-live, Gas Industry Co must also determine and publish a breakdown of the actual critical contingency development costs. The breakdown of actual costs is shown below.
| Cost categories | Actual Cost ($) |
| Cost of review and recommendation of proposed CCMPs | 42,580 |
| Costs payable to CCO | 139,115 |
| Costs of the industry body | 33,216 |
| Total critical contingency development costs | 214,911 |
| Amount recovered through market fees | 219,500 |
| Over-recovery | 4,589 |
No less than 10 business days after publication, Gas Industry Co is required to invoice, or issue a credit note to, every person who paid the development fee, with the difference between that person’s share of the actual development costs and the development fee paid by that person.
A critical contingency was declared at 19:36 on 13 July 2010 and was terminated at 22:34 on 13 July 2010.
Under the Gas Governance (Critical Contingency Management) Regulations 2008, a number of reports have been published in respect of this event: