Summary of Submission
(all references to Schedule 1, Part 5) | Response and Proposal |
| Clause 2(1) and 2(2) - | |
| Pipeline owners are required to show the physical location of the whole distribution system. Some have just shown the general reticulation area by shading maps, which is inadequate. Level of detail should be specified in the Regulations. | Clause 2(1) (distribution networks) only requires a map of that part of the network supplying off-take points > 20TJ pa, not the whole distribution system. Clause 1(2) refers to "physical location" as "by common place name or street address".
What is intended is a map that enables clear identification of the extent of the reticulation in terms of streets reticulated. It is proposed to amend Clause 2 as follows: - 2(1)(a) and 2(2)(a): Add after "physical location" the words "(which enables clear identification of the extent of the reticulation within individual streets)".
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| Clauses 4(2) and 5(1) - | |
| In a distribution network, capacity modelling is undertaken using coincident maximum hourly demands, i.e. maximum hourly demands of individual customers with a diversity factor applied. There are three problems with clause 4(2): | It is proposed to amend Schedule 1 Part 5 Clause 4(2) and 5(1) as follows: |
- The requirement to disclose the date of the peak day for the off-take point seems to have little relevance.
| - 4(2)(a): Amend to require disclosure of the month with the peak daily average for the off-take point (instead of the date of the peak day).
This information should be more readily available than the date of the peak day and would provide the same value by disclosing whether the off-take point has a winter or summer peak demand. |
- The assumption that the system peak hour (and therefore maximum utilisation of the capacity of the system) occurs on the system peak day.
| - 4(2)(b): Amend to require disclosure of the off-take point's throughput of gas (in GJ) in the off-take point's peak hour.
This figure would represent the maximum hourly demand of the off-take point. |
- The assumption that the peak hour of the off-take, and throughput in the peak hour for the off-take on the peak day, are relevant to the system capacity model.
| - 4(2)(c): Amend to require disclosure of the off-take point's throughput of gas (in GJ) in the system peak hour.
This figure would show the coincident maximum hourly demand of the off-take point, and should equate to the diversified throughput of the off-take as used in the capacity simulation model. - 4(2)(d): Amend to require disclosure of the numerical factor by which the throughput of gas at the off-take point in the peak hour of the system may be increased.
This factor would indicate the excess capacity, and may be identified from the capacity model when the minimum system operating pressure is simulated. |
| Peak hour flows on the peak day do not seem relevant, and the data is difficult to record. Suggest that the peak day and the peak hour be disclosed (whether or not the peak hour occurs on the peak day). | - 5(1): Delete words "on the peak day" (which would leave the throughput of gas in the peak hour).
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| Clauses 3(1), 4(3) and 4(4) - | |
| Peak weeks are meaningless. The day of the peak MDQ is significant. | - It is proposed to amend "week" to "day" in 3(1)(a), 3(1)(b), 3(1)(c), 4(4)(a), 4(4)(b) and 4(4)(c).
It is understood the most relevant design period for transmission systems is closer to day than week, so information based on day would be more relevant. |
| Drop the off-take points disclosure thresholds. Require disclosure of: | There are good reasons for thresholds. Covering all off-take points would multiply compliance costs. |
- Design MHQ and actual MHQ for all sales gates.
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- Design MDQ and actual MDQ for each pipeline, including laterals based on the inlet to each pipeline system
| The dates of the peaks for the off-take points are already required to be disclosed (see Clause 4(4)(a)) |
- When the actual peaks are recorded at sales gates and on pipelines.
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- Design inlet pressures for each lateral.
| Capacity modelling data such as design and minimum operating pressures should be disclosed as part of the methodology disclosure (see Clause 7) |
| Clause 6(2) - | |
| The cost of compiling the information required is particularly onerous, and no person has made use of the information in this part of NGC's 1996/1997 disclosure. It is suggested clauses 6(2)(b) and (c) be deleted, and instead make it a requirement to make the information available on request, at cost. | Clauses (b) and (c) are somewhat open ended and therefore could be regarded as onerous. Where transmission capacity is inadequate to meet a significant new load it would seem prudent for the party with the potential requirement to approach NGC Transmission sooner rather than later to ensure adequate planning time is available to determine the best solution. We understand NGC has established confidentiality protocols to provide for the protection of confidential information.
It is proposed that clauses 6(2)(b) and (c) be altered to require provision of this information on request for a specific off-take point. |