Background

An industry group was established in 2013 to progress the recommendations of a Panel of Expert Advisers (PEA) in respect of the Gas Transmission Investment Programme (GTIP). The group was originally known as the Gas Industry Experts Working Group (GIEWG) and latterly as the Gas Industry Transmission Access Working Group (GITAWG). The GIEWG developed a work programme that included a set of VTC changes one of which was to change the code change process itself. The aim was to consolidate the lessons learned from past code changes, and to introduce a more ‘collaborative approach’.

Since the VTC was introduced in 2007, parties could (and often did) change the code without Gas Industry Co’s involvement. Gas Industry Co only became involved when one of the parties appealed a decision to make (or not to make) a proposed code change. However, recognising the special nature of the proposed change to the VTC’s amendment process, the GIEWG decided to seek Gas Industry Co’s views on the proposal, as well as the views of other stakeholders. On 19 November 2014 the GIEWG sent Gas Industry Co an early copy of the proposed change, still subject to final drafting comments from Shippers.

Gas Industry Co provided favourable comments to the GIEWG on 18 December 2014. That letter and the proposed change to the change request can be found below in Related Documents, which also includes the 1 April 2015 VTC which incorporates the new process and GITAWGs Quarterly Report to 31 December 2014 which discusses the group's progress.

Original VTC change process

The original process for VTC changes provided that the VTC could be changed if Vector and 75% of the shippers who voted on the proposed change agreed to it.  However, within 5 business days of voting on a change, Vector or any shipper could lodge an appeal to GIC to seek to have the change allowed or disallowed.  If that occurred, Gas Industry Co would consult on the matter and determine whether or not the change should proceed.

Except when a proposed change was appealed, there was no opportunity for Gas Industry Co or other stakeholders to comment on a change proposal.

New VTC change process

Under the re-designed process introduced on 1 April 2015, notice of a proposed change to the VTC is first published in outline form on the Open Access Transmission Information System (OATIS).  A consultation process then occurs, before Vector shippers vote on the proposal.  Unlike the current process, there is no ability for a party to appeal a proposed change to Gas Industry Co. Instead, Gas Industry Co and other non-VTC stakeholders have an option to provide input during the consultation process. In summary, the new process is:

1. The promoter of a change (Vector or a Shipper) publishes a Change Request Notification summarising the change, why it is necessary and what its effect is likely to be.
2. Within 15 business days after publication of a proposed change, Vector, shippers and other stakeholders (including Gas Industry Co) may publish responses stating whether or not they support in principle the proposed change. 
3. Within a further 10 business days, the promoter can then issue a Draft Change Request including a version of the VTC showing the proposed change. 
4. For 15 business days after publishing the proposed wording, Vector and shippers consult on the variation.  Vector or a shipper may publish a response to the Draft Change Request stating whether it supports the proposed change in principle, any specific objections to it and any conditions to its support. Gas Industry Co or any other stakeholder may also publish a response setting out its views on the proposed changes.
5. Within 5 business days after the consultation period, the issuer of the Draft Change Request may issue a Final Change Request including a summary of the proposed change, a response to any substantive specific objections raised on the Draft Change Request, and an amended version of the Code showing the proposed change in track changes.
6. Within 15 business days after publication of the Final Change Request, Vector and the shippers may publish their position (and are deemed to consent if they don’t do so). 
7. The Final Change Request is passed if Vector and 75% of shippers agree it. 

Summary comparison of Original and New processes