Circumstances of the Breaches. 3.1 As of 21 May 2015, 62,768 of Contact’s category 1 interim certified metering installations had expired certification. This represented approximately 41% of Contact’s total category 1 metering installations.
3.2 In 2011, Contact started deploying AMI meters to displace the existing standard metering. In 2014, despite contracting arrangements being in place, Contact realised it would not achieve compliance by 1 April 2015.
3.3 Consequently, Contact initiated a statistical sampling programme. Contact completed this first programme on 27 March 2015, which resulted in the re- certification of approximately 67,000 meters.
Circumstances of the Breaches. 3.1 The grid owner’s equipment is located on Genesis Energy’s site at Huntly.
3.2 In October 2013, during a maintenance shutdown at Huntly, Genesis Energy identified a possible problem with the duplicate protection for Huntly Unit 5 (HLY5). The grid owner and Genesis Energy had several discussions to identify the problem and how to remedy it.
3.3 In May 2014, following an investigation by the grid owner, it was confirmed that the grid owner’s trip relay circuits (trip 1 and trip 2), component of the HLY5 cable connection differential protection for the 220 kV circuit breakers, were both using the same d.c. supplies. The cable connection differential protection is designed to operate for faults that occur between Huntly's 220 kV circuit breakers and the HLY5 generator transformer.
3.4 The grid owner advised this design has existed since HLY5 was commissioned in June 2007. The investigator notes the design for the grid owner’s protection systems was completed in August 2005 while the duplicated main protection systems requirements were introduced by the Rules on 31 May 2007.
Circumstances of the Breaches. 3.1 On 17 November 2015, the grid owner commissioned a new 66 kV feeder at its Southbrook substation providing supply to MainPower.
3.2 At 20:01 on 24 March 2016, the Islington–Southbrook 1, Islington–Southbrook 2, Ashley–Southbrook 1 and Southbrook–Waipara 1 circuits tripped, resulting in a loss of supply to the Southbrook and Kaiapoi substations.
3.3 Following an on-site inspection at Southbrook, the grid owner returned the two Islington–Southbrook circuits to service at 21:39. The grid owner restored all of the remaining 66 kV circuits between Southbrook, Kaiapoi and Ashley by 22:27.
3.4 The grid owner then proceeded to liven the 66 kV feeders supplying MainPower. When the grid owner closed the Southbrook circuit breaker 152 supplying the MainPower 66 kV Burnt Hill feeder, all of the incoming circuits to Southbrook tripped.
3.5 At that point, the grid owner determined that a fault on the MainPower Burnt Hill feeder had probably led to the initial and subsequent tripping. At 23:39, the grid owner returned to service the transmission circuits between Islington, Southbrook, Kaiapoi and Ashley, but left Southbrook circuit breaker 152 in the open position.
3.6 The fault analysis concluded that:
(a) a high resistance yellow-phase-to-earth fault on the MainPower 66 kV network caused the circuit trips
(b) the directional earth fault final time protection at the grid owner’s Islington, Ashley, and Waipara substations cleared the fault indiscriminately. The grid owner’s protection setting on the new Southbrook 66 kV feeder circuit breaker 152 supplying MainPower appeared to cause the circuit trips.
3.7 The grid owner had set the earth fault protection time delay for the new feeder to operate in three seconds, in accordance with its protection setting guide. The rest of the earth fault protection on the 66 kV Southbrook bus was set to operate in one second. These settings meant that the 66 kV circuits into Southbrook tripped before feeder circuit breaker 152 could trip.
3.8 MainPower confirmed to the grid owner that its line differential protection elements, which should have operated for this high resistance fault, were disabled because MainPower had not yet commissioned its protection signalling between Southbrook and Burnt Hill.
3.9 MainPower had previously advised commissioning staff on site that the protection signalling would not be available when MainPower commissioned the new feeder on 17 November 2015. The grid owner believes this information was not rela...
Circumstances of the Breaches. 3.1 On 11 December 2019, 23 January 2020, 31 January 2020 and 3 February 2020 Auckland Commercial failed to provide the minimum security to the clearing manager by 4:00 pm on the relevant days.
3.2 On each occasion the failure by Auckland Commercial to provide the minimum security caused events of default requiring the clearing manager to institute the default procedure in subpart 7 of Part 14 of the Code.
3.3 The events of default were resolved when Auckland Commercial provided the required security shortly after the deadline.
Circumstances of the Breaches. 3.1 Alpine is 100% owned by the South Canterbury community and is part of the SmartCo Limited (SmartCo) project, the metering equipment provider (MEP) project for managing the deployment of smart meters. In 2010, Alpine began replacing its interim certified category 1 metering installations to achieve compliance by 1 April 2015.
3.2 In early 2014 Xxxxxx decided to join the SmartCo project and to roll out smart meters. As a result, Alpine stopped its own replacement programme, with 12,616 metering installations remaining uncertified as at 21 May 2015. The uncertified meters comprise 55.5% of Alpine’s category 1 metering installations.
3.3 SmartCo started the smart meter roll out on Alpine’s network in November 2014 and originally intended to replace all of its category 1 meters by 31 August 2016. Following discussions with Alpine's compliance manager, it now seems unlikely that Alpine will meet this deadline because of a lack of qualified installers and other resources.
3.4 In May 2015, Alpine submitted a compliance plan to the Authority, showing that it intended to recertify its non-compliant meters by statistical sampling to achieve compliance earlier than August 2016. However, recent sampling revealed that there is a high level of inaccuracy amongst very old metering installations, which means that Alpine will face difficulties achieving compliance in the near future.
Circumstances of the Breaches. 4.1 On 15 October 2012, Meridian requested a change to the instantaneous reserve quantities for Benmore under its ancillary services contract with the system operator. On 17 October 2012, the system operator sent Meridian a letter of variation to the contract reflecting the updated quantities. Meridian signed the letter and returned it to the system operator on 18 October 2012. The effective date of the change was 26 October 2012.
4.2 On 24 April 2013, Meridian queried with the system operator why reserve offers for Benmore were not clearing in the market. The system operator identified that some Meridian offers were being rejected and not included in the price-responsive and non-response schedules, and therefore not being dispatched.
4.3 The system operator discovered that the contract amendments agreed with effect from 26 October 2012 had not been updated in the market system tools. When an offer for Benmore reserves was received by the market system, if it exceeded the contract levels that had applied before 26 October 2012, the entire offer was rejected and the market system automatically used the last valid offer from Meridian for Benmore reserves in place of the rejected offer.
4.4 The market system use of the last valid offer was in accordance with clause 13.8B concerning deemed reserve offers.
4.5 At 15:00 on 24 April 2013, the system operator updated the maximum quantities for Benmore’s instantaneous reserves in the market system to reflect the amended contract.
4.6 On 29 April 2013, Meridian claimed a pricing error for trading periods 1 to 9 on 24 April 2013. The pricing error claim was upheld and the Authority directed the pricing manager to direct the system operator to validate Meridian’s reserve offers using the correct reserve limits and for the pricing manager to recalculate and republish interim prices.
4.7 The system operator considers that had Meridian contacted it earlier to check whether it had received the reserve offer in accordance with clause 13.51(3), the system operator would have identified error earlier and the market impact would have been reduced.
4.8 Meridian submitted Benmore’s offers within the Waitaki River dispatch block offer and its visibility was that the overall block offer was accepted by the Wholesale Information Trading System (WITS). However, Meridian had no visibility in the offer upload screen or any readily immediate visibility that the system operator had subsequently rejected the Benmore reserve offers.
4.9 ...
Circumstances of the Breaches. 3.1 WPI bids for electricity for the total usage at its Karioi pulp mill and offers IL from its pulp refiners.
3.2 WPI prepares in advance the next week’s production schedule including bids and offers for each 8 hour production shift. The schedule notes offers to apply for planned maintenance within a production shift. The schedule is sent to WPI’s trading agent who submits the bids and offers into the information system.
3.3 WPI has an automated alarm system to identify when the refiner load is insufficient to provide the offered IL. The alarm can only be preset to one level for each production shift. Production shifts are from 06:00-14:00, 14:00-22:00 and 22:00-06:00. The alarm is reset as required during production shifts to match changes to IL offers.
3.4 On 11 January 2011 from 06:30 to 12:00, a plate change was scheduled for one of the refiners for which WPI submitted reduced offers for the outage. WPI did not submit revised bids for the outage. For the entire production shift from 06:00 to 14:00 on 11 January 2011, WPI had preset the alarm to the level of IL available during the scheduled outage.
3.5 The refiner plate change commenced from 06:30 and coincided with the scheduled reduction in reserve offers. At 12:00, WPI’s offers reverted to the level available from full refiner load, however, the actual refiner load was still at the level of the outage. The alarm remained set at the level of the refiner outage, therefore the alarm did not activate to indicate load was below the offered level. WPI mistakenly took the outage level as the scheduled offer and therefore did not inform its trading agent of the required change to its offer.
3.6 At 14:00, the commencement of the next shift, WPI’s alarm was activated to show that WPI was below the level required to meet its scheduled IL offers. The WPI operator acknowledged the alarm and reduced the offered values on the WPI control screen to what the operator thought the IL offers were. The change was made by the WPI operator without communication with WPI’s trading agent. This was because the WPI operator at the shift change at 14:00 had mistakenly interpreted comments on the WPI control screen that WPI’s trading agent was already aware of the lower bids and offers that applied from 14:00.
3.7 At 17:45, WPI’s load increased and WPI advised its trading agent to increase WPI’s bids and offers. At this point WPI was informed by its trading agent that it should have already been at the level of the revised bid...
Circumstances of the Breaches. 3.1 The White Hill Wind Farm, commissioned in July 2007, is embedded in a part of The Power Company Limited’s Network that connects to the Grid at the North Makarewa (NMA) substation.
3.2 The metering information that the Grid Owner calculated and provided to the Pricing Manager between 5 August 2007 and 25 October 2007 was equal to the sum of Electricity flowing from the Grid through the two transformers at NMA. The calculation, which the Grid Owner used, did not account for Electricity flowing the other way through the NMA transformers and out into the Grid in situations where the Electricity generated by the wind farm exceeded the connected load.
3.3 Consequently, once the wind farm was commissioned, the demand figures calculated and provided by the Grid Owner to the Pricing Manager for NMA were incorrect whenever generation from the embedded White Hill Wind Farm exceeded the connected load. In those instances, the metering information calculated and provided was zero when it should have been a negative number. The incorrect data affected Final Prices and therefore had a market impact that could not have been resolved by a Washup.
3.4 Initially, the Grid Owner’s metering contractor Energy Market Services Limited1 (EMS) detected discrepancies between the calculated metering 1 EMS is the Grid Owner’s subcontractor for certain of the Grid Owner metering obligations under the Rules. information and the check data from SCADA while undertaking validation checks but incorrectly attributed those to be due to the check data used. This incorrect understanding continued through July to September 2007 while the discrepancies increased.
3.5 On 24 October 2007, EMS contemplated the possibility of the discrepancies not being due to the check data used and sought clarification from Transpower Market Services on how it should be calculating metering information. EMS received advice from Transpower Market Services that connected load should be net quantities and give negative values when generation exceeded connected load.
3.6 On 26 October 2007 EMS corrected the demand calculation.
Circumstances of the Breaches. 3.1 On 27 November 2007 Simply Energy, as an agent for ESD Power, advised Mighty River Power, that it would be converting a building from a Network extension CPK0111 UNET GN (parent Network) to the Embedded Network EMB011 ESDP EN on 1 December 2007.
3.2 Simply Energy provided a mapping of existing ICPs to new ICPs and requested that Mighty River Power change the status of the existing ICPs on the parent Network to ‘inactive’ as of 1 December 2007.
3.3 Other Retailers trading on different ICPs in the same building were similarly provided with the mapping of existing ICPs to new ICPs and were requested to set the status of the ICPs they were trading on to ‘inactive’. These Retailers did so.
3.4 Mighty River Power was the only Retailer which did not change the status of the existing ICPs to ‘inactive’, and for data submission to the Reconciliation Manager on 8 January, 7 February and 6 March 2008, submitted the volumes for these ICPs against the parent Network. Mighty River Power is currently still using these ICPs.
3.5 Simply Energy, acting as an agent for ESD Power, set up new ICPs for each Point Of Connection on the Embedded Network EMB0011 ESDP EN. The ICPs on the parent Network, the status of which the other Retailers set to ‘inactive’, have been decommissioned.
Circumstances of the Breaches. 3.1 On 1 April 2020, Flick reported to the Authority that Genesis had breached clause 11.15AA of the Code.
3.2 Clause 11.15AA requires that a losing retailer must not contact any customer who is switching from the losing retailer to a gaining retailer for anything other than ‘administrative’ reasons. The clause came into effect on 31 March 2020.
3.3 Genesis began adapting internal systems and processes to ensure compliance with the Code amendment when it came into force, including: providing an email to all relevant staff noting the correct date effective of 31 March 2020; workshop with team leaders to discuss the new rules and compliance plan; meeting between Genesis regulatory advisor and the Authority to clarify interpretation of the new rules; suppression of information on switching customers for 180 days; preventing sales staff from intentionally approaching these customers; reprioritising staff to compliant acquisition and retention activity.
3.4 An internal error in interpreting the effective date of the Code amendment resulted in Genesis designing protocols to ensure compliance coming into effect on 1 April 2020, 24 hours after the Code amendment came into force.
3.5 On 31 March 2020, Genesis called a Flick customer who had switched from Genesis on 25 March 2020 and offered a lower price than Flick to entice the customer back to Genesis. The customer declined the offer made by Genesis and reported the attempted winback to Flick.
3.6 Following a fact-finding letter from the Authority advising of the breach, Genesis realised its mistake and advised that on 31 March 2020, they made 224 win-back attempts to customers from 20 different electricity retailers.
3.7 Genesis withdrew offers made on 31 March 2020, to customers who did not accept on the day.
3.8 On 24 April 2020, Electric Kiwi reported to the Authority that Genesis had breached clause 11.15AA of the Code in relation to six ICPs. Two of the ICPs overlapped with the self-reported data provided by Genesis, the other four were unique, new ICPs.
3.9 Following a verbal update of the additional allegations by Electric Kiwi against Genesis, the Committee appointed Xxxxx Xxxxx as investigator, on a temporary basis under regulation 12 of the Enforcement Regulations to investigate all alleged breaches of clause 11.15AA against Genesis.
