This discussion paper builds on the feedback received from stakeholders earlier in the year (2006). Gas Industry Co has undertaken both quantitative and qualitative analysis of options for development of a wholesale market and this discussion paper recommends a modular approach to implementation. In the first instance, it is proposed to issue a standard gas trading agreement as a means to achieving common standards for gas trading and to reduce transaction costs for market participants. The paper also recommends that a simple matching platform could be put in place for modest cost and would be expected to achieve additional transactional efficiencies. Gas Industry Co will take into account feedback received on the paper when undertaking the detailed design of wholesale market arrangements.