Wholesale Retail Code Change Proposal – Ref CPW128

Date17 November 2022
1
Wholesale Retail Code Change Proposal Ref CPW128
Modification
proposal
Wholesale Retail Code Change Proposal Ref CPW128 Updating
Volume Validation Tolerance
Decision
The Authority has decided to approve this Change Proposal
Publication date
17 November 2022
Implementation
date
12 May 2023
We are approving this Change Proposal.
CPW128 has identified that a significant number of meter reads are being incorrectly
rejected due to overly restrictive Volume Validation requirements within the Central
Market Operating System (CMOS). We consider the proposed solution should help
resolve this issue and allow increased numbers of meter reads to be accepted into CMOS
upon first submission. Through amending the Upper and Lower Volume Thresholds, a
large reduction in the current read rejection rate can be expected. As a result, overall
data quality should improve with fewer incorrect rejections, and the process of data
entry will be more efficient.
We support adjusting the Prior Estimate Daily Volume (PEDV) calculation to improve the
accuracy of validation rules. We also support the proposal to allow vacant premises to
register readings of '0' (zero). Improved validation thresholds should help Retailers to
identify where genuine problems exist with meters and, where necessary, prompt
Retailers and Wholesalers to collaborate in finding and resolving issues as swiftly as
possible. We consider that this should result in benefits for customers, as issues with
meters will be identified and addressed in a timelier manner.
The ongoing reform of the Market Performance Framework (MPF) also provides an
opportunity to strengthen incentives for Retailers to update CMOS with accurate data in
a timely manner, and ensure metering assets are in good working order. We consider
that this change proposal should support the MPF reform through increasing market
confidence that the data entering CMOS is more accurate and reflective of actual meter
reading activities.
We are supportive of a Post-Implementation Review (PIR) of this change proposal. We
suggest that the PIR considers monitoring the unwinding of automated re-submissions
that some Retailers currently employ to over-ride current validation processes. This

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