Victorian Gas Industry 
Market and System Operations Rules

Version 2.2B
30 November 1998

101  Collins  Street  Melbourne   Victoria   3000   Australia
GPO  Box  128A  Melbourne  3001
Telephone  (03)  9288 1234  Facsimile  (03)  9288 1567  DX  240  Melbourne
Reference:  SET:JGA:TVJ:20039040
C/982320078/982320079 
MELBOURNE     SYDNEY     PERTH     CANBERRA     BRISBANE     SINGAPORE     HANOI     HO CHI MINH CITY
CORRESPONDENT   OFFICE   IN   JAKARTA

Liability is limited by the Solicitors Scheme under the Professional Standards Act 1994 (NSW)

INDEX
CHAPTER 1	INTRODUCTION
1.1	Purpose and Application of Rules........................................................2
1.2	VENCorp..............................................................................................4
1.3	Enforceability and Amendment of these Rules.....................................7
1.4	Public Consultation Procedures.............................................................8

CHAPTER 2	REGISTRATION
2.1	Registration with VENCorp................................................................10
2.2	Ceasing to be a Market Participant......................................................12
2.3	Suspension...........................................................................................12
2.4	Liability of deregistered Participants...................................................13
2.5	Intention to commence activities or functions.....................................13
2.6	Market fees...........................................................................................13
2.7	Previous Financial Year Report...........................................................16

CHAPTER 3	MARKET OPERATION AND ADMINISTRATION
3.1	Gas Scheduling....................................................................................18
3.2	Determination of Market Price............................................................30
3.3	Participant Compensation Fund...........................................................34
3.4	EoD Linepack......................................................................................37
3.5	Allocation and Reconciliation..............................................................39
3.6	Settlements...........................................................................................47
3.7	Prudential Requirements......................................................................68

CHAPTER 4	TECHNICAL MATTERS
4.1	Connection to the Transmission System..............................................75
4.2	LNG Storage........................................................................................82
4.3	Gas Quality..........................................................................................89
4.4	Metering...............................................................................................93
Schedule 4.1	Metering Uncertainty Limits and Calibration....................................110
Schedule 4.2	Metering Register...............................................................................112
Schedule 4.3	Installation Database..........................................................................114

CHAPTER 5	MARKET INFORMATION AND SYSTEM PLANNING
5.1	Market Information............................................................................116
5.2	Forecasts and Planning and Maintenance Reviews ..........................120
5.3	MDQ Authorisation...........................................................................127
5.4	Confidentiality...................................................................................133

CHAPTER 6	INTERVENTION AND MARKET SUSPENSION
6.1	Overview...........................................................................................137
6.2	Emergencies......................................................................................139
6.3	Emergency Planning by Participants.................................................141
6.4	Emergency Curtailment of Customers..............................................142
6.5	Response to an Emergency................................................................144
6.6	System Security Threat......................................................................148
6.7	Force Majeure and Market Suspension..............................................152
6.8	Review of Chapter 6..........................................................................156
6.9	Savings..............................................................................................157

CHAPTER 7	ENFORCEMENT AND DISPUTES
7.1	Enforcement......................................................................................159
7.2	Dispute Resolution............................................................................161
Schedule 7.1	Classification of Rules .....................................................................171

CHAPTER 8	RULES CHANGES...........................................................................210

CHAPTER 9	TRANSITIONAL ARRANGEMENTS AND DEROGATIONS
9.1	Transitional arrangements..................................................................217
9.2	Derogations........................................................................................221

CHAPTER 10	INTERPRETATION..........................................................................223

CHAPTER 11	GLOSSARY......................................................................................230

CHAPTER 1.	INTRODUCTION

1.1	PURPOSE AND APPLICATION OF RULES

1.1.1	The Market and System Operations Rules
(a)	These Rules are the Market and System Operations Rules.
(b)	In these Rules:
(1)	words and phrases which appear in italics are defined in the glossary in chapter 11; and
(2)	technical concepts relating to gas measurement are described in clause 10.4.
(c)	These Rules must be interpreted in accordance with the provisions of chapter 10.
1.1.2	Purpose
The purpose of these Rules is:
(a)	to provide an efficient, competitive and reliable market;
(b)	to regulate the operation of the market;
(c)	to regulate the activities of Participants in Victoria in and in relation to the transmission system and the market; and
(d)	to regulate the operation of the transmission system in Victoria by VENCorp in a way which:
(1)	minimises threats to system security;
(2)	encourages the achievement of the market objectives; and
(3)	enables access to the transmission system and the market.
1.1.3	The regulatory framework
These Rules form part of the regulatory framework which: 
(a)	is applicable to the owners, operators and users of the transmission system under the Gas Industry Act; and
(b)	may also be applicable to the owners and operators of transmission pipelines as part of their access arrangements, required by and applicable under the Access Code,
which is represented diagrammatically below.

REGULATORY FRAMEWORK

GAS INDUSTRY ACT  (VIC) 1994

Retail Licence

Distribution Licence

  Participants
• Retailers
• Distributors 
• Producers
• Traders
• Storage Providers
• Transmission
   Customers
• Distribution
   Customers
• Transmission
   Pipeline Owners
• Interconnected
   Pipeline Owners

Victorian Access Code

Office of the Regulator-
General
(Distribution)

Access
Arrangements

MSO Rules
VENCorp

Tariff Order

ACCC
(Transmission/
MSOR)

Distribution
System
Code
(including retail metering)

1.1.4	Operation
The commencement date of these Rules is [			].
1.1.5	Application of these Rules
(a)	A person other than VENCorp who:
(1)	is bound to comply with these Rules under the Gas Industry Act and/or as part of an access arrangement; and/or
(2)	holds a retail licence under the Gas Industry Act and sells gas to Customers which has been transported through the transmission system; and/or
(3)	wishes to undertake activities or participate in the market,
must register with VENCorp in accordance with chapter 2.
(b)	Subject to clause 1.1.6, a person who is registered with VENCorp as a Participant under chapter 2 is bound by these Rules.
1.1.6	System Bypass
Nothing in these Rules limits the rights of any person to construct, own or operate a pipeline or pipeline equipment which is not part of the transmission system and which is not subject to these Rules.

1.2	VENCorp
1.2.1	Obligations of VENCorp
(a)	VENCorp must:
(1)	operate the transmission system; and
(2)	operate and administer the market,
in accordance with these Rules and taking into consideration the market objectives and VENCorp must allocate appropriate resources to enable it to do so.
(b)	VENCorp must maintain and publish a register of Participants and must update and publish the register whenever a person becomes or ceases to be a Participant.
(c)	In consultation with Participants, VENCorp must develop and update from time to time system security guidelines in accordance with which VENCorp will be required to operate the transmission system in a way which minimises threats to system security, and the system security guidelines must be provided to:
(1)	the Regulator on completion and after any update of the system security guidelines; and
(2)	Participants and interested persons on request.
(d)	Should VENCorp propose a change to the system security guidelines which, in VENCorp’s reasonable opinion is a material change then, prior to its implementation, that proposed change must be reviewed in accordance with the public consultation procedures.
(e)	VENCorp must monitor daily trading activity in the market:
(1)	with a view to ensuring that such trading is performed in accordance with these Rules; and
(2)	to identify any significant price variations in and between trading intervals.
(f)	If VENCorp identifies any significant price variations in and between trading intervals, VENCorp must, within ten business days of identifying those matters, prepare a report setting out the identified significant price variations.
(g)	VENCorp must provide a copy of the report referred to in clause 1.2.1(f) to:
(1)	the Regulator on completion of the report; and
(2)	Participants and interested persons on request.
(h)	VENCorp must, in consultation with the Regulator, develop guidelines as to what constitutes a significant price variation.
(i)	Where these Rules require VENCorp to develop procedures, processes or systems, VENCorp must do so after taking into consideration the likely costs to Participants of complying with those procedures or processes and of obtaining, installing or adopting those systems, as the case may be.
(j)	VENCorp must comply with each of the requirements and obligations imposed on it under these Rules.
(k)	For the purposes of the Tariff Order, the obligations and functions of VENCorp as described in this clause 1.2.1, are the tariffed VENCorp services.
1.2.2	Limitation of liability of VENCorp
VENCorp is not to be liable for any loss or damage suffered or incurred by a Participant or any other person as a consequence of any act or omission by VENCorp, except:
(a)	as expressly provided for in these Rules; 
(b)	to the extent that VENCorp can and does recover compensation from any Participant or any other person in respect of any such loss or damage, after deducting its costs, if any, of recovering that compensation; and
(c)	to the extent that VENCorp can and does recover compensation under a policy of insurance in respect of any such loss or damage, after deducting its costs, if any, of recovering that compensation.
1.2.3	Review of VENCorp liability
(a)	VENCorp must undertake a review of the provisions of these Rules which limit VENCorp’s liability in accordance with the public consultation procedures.
(b)	VENCorp must initiate the review referred to in clause 1.2.3(a) prior to the commencement date and complete the review within three months of the commencement date.
(c)	As soon as practicable after the review referred to in clause 1.2.3(a) has been conducted, VENCorp must produce a report on the review and that report must:
(1)	be provided to the Regulator upon completion; and
(2)	made available to other interested parties upon request.
(d)	The findings of the report must be considered by VENCorp in consultation with the Regulator.
1.2.4	VENCorp performance
(a)	Unless otherwise expressly provided in these Rules, nothing in these Rules is to be construed as imposing upon VENCorp any obligation or duty to, or enforceable by, a Participant or any other person and a Participant must not make any commitment to any person binding on or purporting to bind VENCorp.
(b)	Nothing in these Rules prevents VENCorp from exercising any right or remedy which it may have against a person at law or pursuant to the Gas Industry Act or otherwise.
(c)	In exercising its discretions and performing its obligations under these Rules, VENCorp must at all times:
(1)	act in a reasonable and prudent manner; and
(2)	act reasonably and in good faith in its dealings with Participants;
except to the extent that:
(3)	there is any standard of performance already provided for by any statute, regulation or licence condition to which VENCorp is subject; or
(4)	VENCorp would thereby be required to act in a manner which would conflict with any requirement of law.
(d)	For the avoidance of doubt the operation of clause 1.2.4(c) does not prevent VENCorp from performing any obligation under these Rules.
(e)	At least once in every calendar year, VENCorp must publish performance indicators which provide an indication of, and monitor, VENCorp’s performance under these Rules in respect of the VENCorp functions and the market objectives.

1.3	ENFORCEABILITY AND AMENDMENT OF THESE RULES
1.3.1	Enforceability
These Rules are enforceable in accordance with chapter 7.
1.3.2	Changes to these Rules
Amendments to these Rules must be made in accordance with chapter 8.

1.4	PUBLIC CONSULTATION PROCEDURES
Where these Rules identify matters which are subject to review or consultation in accordance with the public consultation procedures, VENCorp must ensure that, as a minimum, the following procedures are followed:
(a)	VENCorp must advertise particulars of the matter to Participants and other interested persons, inviting written submissions concerning the matter to be made by a specified date;
(b)	where, in the reasonable opinion of VENCorp, there is a diversity of views expressed in the written submissions received under clause 1.4(a), VENCorp must invite Participants and other interested persons to a meeting or meetings at which those views may be presented and discussed;
(c)	following its consideration of the matter under consultation, VENCorp must prepare a report setting out:
(1)	the matter under consultation;
(2)	VENCorp’s decision in relation to the matter;
(3)	the reasons for VENCorp’s decision;
(4)	the findings on material questions of fact, referring to evidence or other material on which those findings were based; and
(5)	the procedures followed in considering the matter; and
(d)	VENCorp must provide a copy of the report referred to in clause 1.4(c) to:
(1)	the Regulator on completion of the report; and
(2)	Participants and interested persons on request.

CHAPTER 2.	REGISTRATION

2.	REGISTRATION

2.1	Registration with VENCorp
(a)	Each Transmission Pipeline Owner whose transmission pipeline forms part of the transmission system and each person whose pipeline or pipeline equipment, gas production facility or storage facility is connected to the transmission system must register with VENCorp as a Participant (unless that person is an Exempt Person) in any one or more of the following categories:
(1)	Transmission Pipeline Owners;
(2)	Interconnected Pipeline Owners;
(3)	Producers;
(4)	Transmission Customers;
(5)	Distributors; and
(6)	Storage Providers.
(b)	A person who:
(1)	holds a retail licence under the Gas Industry Act; and
(2)	sells gas to Customers which has been transported through the transmission system,
must register with VENCorp as a Participant unless that person is an Exempt Person.
(c)	Subject to clause 2.1(e), a person may apply to VENCorp to be registered as a Market Participant in one or more of the following categories:
(1)	Producers;
(2)	Traders;
(3)	Retailers; 
(4)	Transmission Customers; 
(5)	Distribution Customers; or
(6)	owners and/or operators of LNG storage facilities and other storage facilities.
(d)	A person may not undertake activities or participate in or in relation to the market in a category set out in clause 2.1(c) unless the person is registered as a Market Participant in that category.
(e)	A person is not eligible to be registered as a Market Participant unless the person:
(1)	is a resident in, or is permanently established in, Australia;
(2)	is, in respect of Transmission Customers and Distribution Customers, a person who is a Non-Franchise Customer;
(3)	is not under external administration (as defined in the Corporations Law) or under a similar form of administration under any laws applicable to that person in any jurisdiction;
(4)	is not immune from suit in respect of the obligations of a Participant under these Rules; 
(5)	is capable of being sued in its own name in a court of Australia; and
(6)	has entered into and continues to be a party to an agreement providing for the payment of transmission charges associated with the provision of services by a Transmission Pipeline Owner under a service envelope agreement,
and if at any time a Market Participant ceases to be eligible to be registered as a Market Participant in accordance with this clause 2.1(e), that Market Participant must inform VENCorp accordingly and as soon as practicable after VENCorp becomes aware that a Market Participant is no longer eligible to be registered, VENCorp must issue a suspension notice in respect of that Market Participant in accordance with clause 3.7.7.
(f)	Applications for registration must be submitted to VENCorp in the form prescribed by VENCorp and must be accompanied by a registration fee (if any) fixed by VENCorp.
(g)	If an applicant applies for registration in one of the categories specified in clause 2.1(c), that applicant must satisfy prudential requirements in accordance with clause 3.7 and must provide to VENCorp documentary evidence of its compliance with the relevant prudential requirements with the application for registration.
(h)	Within five business days of receiving an application, VENCorp must advise the applicant of any further information which VENCorp reasonably considers to be required to enable VENCorp properly to assess the application and if VENCorp has not received that further information which it reasonably considers satisfy the relevant application requirements within a further fifteen business days, VENCorp may treat the application as withdrawn and if VENCorp incurs additional costs as a result of requesting and assessing that further information VENCorp may require the applicant to pay to VENCorp a reasonable amount to cover those additional costs.
(i)	If an application for registration in one or more of the categories set out in clause 2.1(a), (b) and/or (c) has been received by VENCorp and:
(1)	all relevant application requirements have been satisfied;
(2)	the applicant is eligible to be registered in the category or categories in which registration is sought;
(3)	VENCorp reasonably considers that the applicant will be able to comply and maintain compliance with these Rules;
(4)	VENCorp reasonably considers that the applicant is of sufficient financial standing or has sufficient credit support to meet its financial obligations; and
(5)	if the applicant seeks registration as a Market Participant, the applicant satisfies any applicable prudential requirements,
then subject to clause 2.1(e), VENCorp must approve the application and register the applicant in the category or categories to which the application relates providing that if the application satisfies the requirements of this clause 2.1(i) in respect of a fewer number of categories than those for which registration is sought, VENCorp must register the applicant only in that category or in those categories in respect of which the requirements of this clause 2.1(i) are satisfied.
(j)	If VENCorp approves an application under clause 2.1(i), VENCorp must send written notice of approval to the applicant within fifteen business days of receiving:
(1)	the application under clause 2.1(f); or
(2)	if further information and/or fees are required under clause 2.1(h), that further information and/or fees,
and registration of the applicant as a Participant will take effect on the date specified in the notice of approval which must be a date not more than seven days after the date on which VENCorp sends the notice of approval under this clause 2.1(j). 
(k)	If VENCorp does not approve an application for registration in a category to which an application relates, VENCorp must send written notice to the applicant advising the applicant that the application is not approved and VENCorp must give reasons for its decision.
2.2	Ceasing to be a Market Participant
(a)	A person may notify VENCorp in writing that it wishes to cease to be registered in any one or more categories of Market Participant set out in clause 2.1(c).
(b)	In a notice given under clause 2.2(a), a Market Participant must specify a date upon which it wishes to cease to be registered.
(c)	On receipt of a notice under clause 2.2(a), VENCorp must notify all Market Participants that the person who gave the notice will cease to be a Market Participant and the date on which that will occur.
(d)	If VENCorp notifies Market Participants that a Market Participant will cease to be registered on a specified date, that Market Participant must cease all trading and all other activities in the market from that date.
2.3	Suspension
(a)	Subject to clause 2.3(b), if a Market Participant receives a suspension notice from VENCorp in accordance with any provision of these Rules, that Market Participant is suspended from participation in the market unless and until VENCorp in its absolute discretion declares the suspension notice to be revoked in accordance with clause 3.7.7.
(b)	If VENCorp issues a suspension notice to any Market Participant under which VENCorp declares that the Market Participant is to be deregistered as a Market Participant, the Market Participant is deemed to be deregistered as a Market Participant from the date specified in the suspension notice.
2.4	Liability of deregistered Participants
Notwithstanding that a person is no longer registered as a Participant for any reason, that person’s obligations and liabilities which arose under these Rules prior to the date on which that person was deregistered remain unaffected by the deregistration.
2.5	Intention to commence activities or functions
(a)	Any person who intends to register as a Participant may register with VENCorp as an Intending Participant if that person can satisfy VENCorp of its bona fide intent to commence an activity which would entitle or require that person to be registered as a Participant once that activity is commenced.
(b)	Applications for registration as an Intending Participant must be submitted to VENCorp in the form prescribed by VENCorp and must be accompanied by the registration fee (if any) fixed by VENCorp from time to time.
(c)	VENCorp may from time to time require an Intending Participant to satisfy VENCorp that it continues to meet the criteria for registration in clause 2.5(a) and if the Intending Participant is unable to satisfy VENCorp that it remains entitled to be registered as an Intending Participant, then VENCorp must send written notice to the relevant Intending Participant to advise the relevant Intending Participant that it will cease to be registered as an Intending Participant on the date specified by VENCorp in that notice.
(d)	An Intending Participant is taken to be an Intending Participant only insofar as its activities relate to its intention to commence an activity that would entitle or require that person to be registered as a Participant.
(e)	An Intending Participant acquires the rights and obligations under these Rules:
(1)	which are applicable to Participants; and
(2)	which are applicable to the category of Participant (as specified in clauses 2.1(a), (b) and (c)) in which that Intending Participant would be entitled or required to be registered once it commences its intended activities.
2.6	Market fees
(a)	VENCorp may charge, and Participants must pay, market fees in accordance with this clause 2.6.
(b)	Subject to clauses 2.6(d) to (h), market fees, which are charged for tariffed VENCorp services must be determined by the Board of Directors of VENCorp, and approved by the Regulator, in respect of each financial year in accordance with the Tariff Order.
(c)	Unless otherwise approved by the Regulator, each Participant must pay to VENCorp market fees in accordance with this clause 2.6(c):
(1)	each Market Participant must pay a registration fee determined in accordance with the Tariff Order for every day or part of a day during which that Market Participant is registered under clause 2.1;
(2)	each Market Participant who withdraws gas from the transmission system on a gas day at a system withdrawal point or injects gas into the transmission system on a gas day at a system injection point must pay, in respect of that withdrawal or injection, a metering fee associated with a “transmission supply point” as defined in the Tariff Order and as determined in accordance with the Tariff Order;
(3)	each Retailer whose Customers have withdrawn gas on a gas day at a transmission delivery point at which there is a meter from which VENCorp is responsible for collecting metering data must pay, in respect of each such withdrawal on that gas day, a metering fee associated with a “transmission supply point” as defined in the Tariff Order and as determined in accordance with the Tariff Order;
(4)	each Retailer whose Customers have withdrawn gas on a gas day at a distribution delivery point at which there is a meter from which VENCorp is responsible for collecting metering data must pay, in respect of each such withdrawal on that gas day, a metering fee associated with a “distribution supply point” as defined in the Tariff Order and as determined in accordance with the Tariff Order;
(5)	each Distribution Customer who is a Market Participant and who withdraws gas on a gas day at a distribution delivery point at which there is a meter from which VENCorp is responsible for collecting metering data must pay, in respect of that withdrawal on that gas day, a metering fee associated with a “distribution supply point” as defined in the Tariff Order and as determined in accordance with the Tariff Order;
(6)	each Retailer who sells gas to Customers who withdraw gas at a tariff V withdrawal point in a financial year must pay a commodity charge determined in accordance with the Tariff Order for each GJ of gas withdrawn by those Customers at such tariff V withdrawal point and sold by that Retailer to those Customers during that financial year;
(7)	each Market Customer who withdraws gas at a tariff V withdrawal point must pay a commodity charge determined in accordance with the Tariff Order for each GJ of gas withdrawn by that Market Customer at that tariff V withdrawal point during each financial year;
(8)	each Retailer who sells gas to Customers who withdraw gas at a tariff D withdrawal point in a financial year must pay a commodity charge determined in accordance with the Tariff Order for each GJ of gas withdrawn by those Customers at such tariff D withdrawal point and sold by that Retailer to those Customers during that financial year;
(9)	each Market Customer who withdraws gas at a tariff D withdrawal point must pay a commodity charge determined in accordance with the Tariff Order for each GJ of gas withdrawn by that Market Customer at that tariff D withdrawal point during each financial year; and
(10)	each Market Participant must pay a system security gas storage charge described as a “system security” charge in the Tariff Order and determined in accordance with the Tariff Order, in respect of each GJ of gas withdrawn from the transmission system by that Market Participant.
(d)	VENCorp must, before submitting its annual statement to the Regulator for approval in accordance with clause 6.1(a)(2) of the Tariff Order, produce an initial report setting out:
(1)	VENCorp’s budgeted expenditures and budgeted revenues for that regulatory year; 
(2)	the amount of proposed market fees in respect of each of the tariffed VENCorp services in respect of which market fees are proposed to be charged for the next financial year;
(3)	the method used in determining the amount of proposed market fees in respect of each of VENCorp’s activities referred to in clause 2.6(d)(2) including but not limited to VENCorp’s estimated costs and expenses associated with those activities;
(4)	other fee structures and fee amounts which are appropriate for comparison purposes; and
(5)	an assessment of the extent to which the proposed market fees comply with the principles set out in clause 8.1 of the Access Code.
(e)	VENCorp must provide a copy of the initial report to:
(1)	the Regulator on completion of the report; and
(2)	Participants and interested persons on request.
(f)	VENCorp must invite Participants and interested persons to make submissions in relation to the initial report and must consider any such submissions received up to ten business days after the initial report is made available to Participants and interested persons under clause 2.6(e)(2).
(g)	VENCorp must prepare a final report which summarises:
(1)	submissions received under clause 2.6(f); and
(2)	the process of consultation undertaken by VENCorp in relation to preparation of the final report.
(h)	VENCorp must provide a copy of the final report to the Regulator at the time of submitting its annual statement to the Regulator for approval in accordance with clause 6.1(a)(2) of the Tariff Order.
2.7	Previous Financial Year Report
(a)	VENCorp must, by no later than two months after the end of each financial year, prepare a report setting out:
(1)	VENCorp’s budgeted and actual expenditures and budgeted and actual revenues in respect of each of the tariffed VENCorp services, including, but not limited to:
(A)	system security;
(B)	collection, storage and processing of metering data and billing and settlement of market transactions; and
(C)	costs of operating the dispute resolution process under clause 7.2;
(2)	an explanation of any significant variation between budgeted and actual expenditures and budgeted and actual revenues; and
(3)	contributions made to and payments made from the participant compensation fund,
in respect of the previous financial year.
(b)	VENCorp must provide a copy of the report prepared under clause 2.7(a) to:
(1)	the Regulator on completion; and
(2)	Participants and interested persons on request.

CHAPTER 3.	MARKET OPERATION AND ADMINISTRATION

3.1	GAS SCHEDULING 

3.1.1	Gas scheduling
(a)	VENCorp must operate the transmission system in accordance with the gas scheduling procedures and these Rules and by scheduling injections of gas into and withdrawals of gas from the transmission system in accordance with nominations and inc/dec offers. 
(b)	When scheduling injections of gas into and withdrawals of gas from the transmission system, VENCorp must use its reasonable endeavours to operate within the system security guidelines.
(c)	Subject always to:
(1)	VENCorp’s obligations under these Rules to schedule injections of gas into, and withdrawals of gas from, the transmission system in accordance with the gas scheduling procedures;
(2)	VENCorp’s obligations under these Rules to operate the transmission system within the system security guidelines and to avert threats to system security; and
(3)	there being sufficient gas available at all relevant times for injection into the transmission system to satisfy demand,
VENCorp must use its reasonable endeavours to ensure that sufficient gas is made available for withdrawal from the transmission system during each gas day to satisfy Market Participants’ aggregate requirements for gas at system withdrawal points.
(d)	VENCorp must develop, document and make available to all Market Participants and Transmission Pipeline Owners the procedures (the gas scheduling procedures), including systems back-up and disaster recovery procedures, which VENCorp will follow, and the algorithm which will be used by VENCorp, for the purpose of scheduling in accordance with this clause 3.1.
3.1.2	Nominations and inc/dec offers
(a)	Each Market Participant who intends to inject quantities of gas into or withdraw quantities of gas from the transmission system on a gas day must submit nominations to VENCorp in accordance with and at the times specified in clauses 3.1.3, 3.1.4  and 3.1.7.
(b)	A Market Participant who is willing to modify the quantities of gas which it intends to inject into or withdraw from the transmission system on a gas day (as specified in the nominations submitted by that Market Participant in respect of that gas day) may submit inc/dec offers in accordance with clauses 3.1.5 and 3.1.7.
3.1.3	Injection nominations
(a)	A Market Participant must submit a separate injection nomination in respect of each system injection point at which it intends to inject gas on a gas day.
(b)	Each injection nomination must specify:
(1)	the gas day in respect of which the injection nomination applies;
(2)	the identity of the Market Participant submitting the injection nomination;
(3)	the system injection point at which the Market Participant submitting the injection nomination intends to inject quantities of gas; and
(4)	the quantity of gas nominated for injection at that system injection point  for each hour of that gas day.
3.1.4	Withdrawal nominations
(a)	A Market Participant must submit a separate withdrawal nomination in respect of each system withdrawal zone from which it intends to withdraw gas on a gas day.
(b)	Each withdrawal nomination must specify:
(1)	the gas day in respect of which the withdrawal nomination applies;
(2)	the identity of the Market Participant submitting the withdrawal nomination;
(3)	the system withdrawal zone from which the Market Participant submitting the withdrawal nomination proposes to withdraw quantities of gas;
(4)	if the Market Participant intends to submit a withdrawal inc/dec offer in respect of that system withdrawal zone for that gas day, the controllable quantity nominated by the Market Participant in respect of that system withdrawal zone; and
(5)	the quantity of gas nominated for withdrawal at that system withdrawal zone for each hour of that gas day.
3.1.5	Inc/dec offers
(a)	Market Participants may make offers (inc/dec offers) to modify the quantities of gas which they will inject into, or withdraw from, the transmission system on a gas day at specified prices in accordance with this clause 3.1.5.
(b)	An inc/dec offer must specify:
(1)	the identity of the Market Participant by whom it is made;
(2)	the gas day to which the offer relates;
(3)	the system injection point (in the case of an injection inc/dec offer) or system withdrawal zone (in the case of a withdrawal inc/dec offer) in relation to which the offer is made; and 
(4)	up to ten price steps.
(c)	Each price step must specify:
(1)	a single price, expressed in $/GJ to four decimal places, which is to apply throughout the gas day; and
(2)	for each hour of the gas day, the total quantity of gas, expressed in GJ, up to which the Market Participant is offering to inject gas into, or withdraw gas from, the transmission system in the hour specified at the price specified in clause 3.1.5(c)(1).
(d)	In the case of an injection inc/dec offer, the quantity of gas specified in a price step (referred to in this clause as the “higher price step”) in respect of any hour must not be less than the quantity of gas specified in respect of that hour in any price step which specifies a price which is less than the price specified in the higher price step.
(e)	In the case of withdrawal inc/dec offer, the quantity of gas specified in a price step (referred to in this clause as the “higher price step”) in respect of any hour must not be greater than the quantity of gas specified in respect of that hour in any price step which specifies a price which is less than the price specified in the higher price step.
(f)	Inc/dec offers may specify the following conditions or constraints, which will be applied by VENCorp in scheduling price steps:
(1)	the period of time required by the Market Participant after the Market Participant receives a scheduling instruction in respect of the offer before the Market Participant will be able to modify the gas flow rate at the relevant system point in accordance with the offer;
(2)	a time by which VENCorp must issue a scheduling instruction in respect of the offer if it is going to do so;
(3)	in the case of an injection inc/dec offer, the minimum quantity of gas which the Market Participant is offering to inject in each hour of the gas day to which the offer relates;
(4)	in the case of an injection inc/dec offer, the minimum quantity of gas which the Market Participant is offering to inject in the gas day to which the offer relates;
(5)	in the case of an injection inc/dec offer, the maximum quantity of gas in each price step which the Market Participant is offering to inject in the gas day to which the offer relates;
(6)	in the case of a withdrawal inc/dec offer, the maximum quantity of gas in each price step which the Market Participant is offering to withdraw in the gas day to which the offer relates;
(7)	in the case of a withdrawal inc/dec offer, the minimum quantity of gas which the Market Participant is offering to withdraw in the gas day to which the offer relates; and 
(8)	for any hour of the gas day, the maximum increase and/or decrease in the gas flow rate relative to the previous hour of the gas day. 
(g)	A Market Participant may only make a withdrawal inc/dec offer in respect of a system withdrawal zone on a gas day if and to the extent that it has:
(1)	nominated a controllable quantity for that system withdrawal zone on that gas day; and
(2)	registered with VENCorp a maximum controllable quantity in respect of that system withdrawal zone in accordance with clause 3.1.6 equal to or in excess of the controllable quantity nominated by that Market Participant for that system withdrawal zone on that gas day.
3.1.6	Accreditation of controllable quantities
(a)	A Market Participant who wishes to submit withdrawal inc/dec offers in respect of a system withdrawal zone, and to receive any ancillary payments resulting from the scheduling of those withdrawal inc/dec offers, must apply to VENCorp for accreditation of the controllable quantities in respect of which the Market Participant intends to submit withdrawal inc/dec offers.
(b)	An application for accreditation must specify:
(1)	the  delivery point to which the application relates;
(2)	details of the load characteristics of the delivery point, including minimum and maximum hourly quantities, minimum and maximum daily quantities and such other information as VENCorp may require; and
(3)	the specific actions that will be taken to increase or decrease withdrawals at the relevant delivery point if a withdrawal inc/dec offer is scheduled by VENCorp and the methods which will be used to verify that those actions have been taken.
(c)	VENCorp will only accredit controllable quantities if the Market Participant seeking accreditation is able to demonstrate to VENCorp’s reasonable satisfaction that it will be able to procure that the gas flow at the relevant delivery point will be modified in accordance with any scheduling instructions issued by VENCorp in respect of such controllable quantities and that compliance with such scheduling instructions can be monitored and/or audited in a manner acceptable to VENCorp.  
3.1.7	Timing of nominations and inc/dec offers
(a)	Each Market Participant must submit nominations in respect of each gas day to VENCorp by no later than 11.00 am on the day which is two days prior to the day on which that gas day starts.
(b)	A Market Participant must submit a nomination in respect of a gas day to VENCorp by no later than:
(1)	9.00 am on the day before the day on which that gas day starts; and
(2)	8.00 am on the same day as the start of that gas day,
if the immediately preceding nomination (including a nomination made pursuant to this clause 3.1.7(b)) made by that Market Participant in respect of the same system point no longer represents that Market Participant’s best estimate of the quantity of gas which it expects to inject into or withdraw from the transmission system at that system point or the timing or gas flow rate of that injection or withdrawal.
(c)	Subject to clause 3.1.7(d), a Market Participant may submit inc/dec offers in respect of a gas day at any time prior to, but not later than, 8.00am on the same day as the start of the gas day in respect of which they are made.
(d)	A Market Participant who intends to submit inc/dec offers in respect of a gas day must submit inc/dec offers which reflect the Market Participant’s best estimate of the quantities and prices which it expects to include in the final inc/dec offers which it intends to submit for that gas day by no later than:
(1)	11.00am on the day which is two days prior to the day on which that gas day starts; and
(2)	9.00am on the day before the day on which that gas day starts.
3.1.8	EoD linepack bids
(a)	By no later than 8.00am on a day, a Market Participant may submit to VENCorp  an EoD linepack bid offering to purchase EoD linepack. 
(b)	An EoD linepack bid must specify:
(1)	the identity of the Market Participant submitting the EoD linepack bid; and
(2)	up to five EoD linepack price steps.
(c)	Each EoD linepack price step must specify:
(1)	a single price, expressed in $/GJ to four decimal places; and
(2)	the total quantity of EoD linepack up to which the Market Participant is offering to purchase at that price.
(d)	The maximum quantity of gas specified in an EoD linepack price step for a gas day (referred to in this clause as the “higher EoD linepack price step”) must not be greater than the maximum quantity of gas specified in an EoD linepack  price step for that gas day which specifies a price which is less than the price specified in the higher EoD linepack price step.
(e)	An EoD linepack bid is an offer to purchase any quantity of EoD linepack that is greater than zero and less than or equal to the maximum quantity specified in the price step in that EoD linepack bid which specifies the lowest price.
(f)	VENCorp may allocate to a Market Participant any quantity of EoD linepack up to the maximum quantity specified in the EoD linepack price step which VENCorp accepts.
3.1.9	Confirmation of nominations, inc/dec offers and EoD linepack bids
(a)	Each Market Participant is responsible for verifying that the information posted on the market information bulletin board relating to its nominations, inc/dec offers and EoD linepack bids is accurate and correct.
(b)	VENCorp is under no obligation to verify that the information posted on the market information bulletin board relating to a Market Participant’s nominations, inc/dec offers or EoD linepack bids is accurate and correct.
(c)	VENCorp must provide acknowledgment of receipt of and, subject to clause 3.1.9(b), validate all nominations, inc/dec offers or EoD linepack bids submitted by Market Participants in accordance with the electronic communication procedures.
(d)	VENCorp must ensure that the information relating to each Market Participant’s nominations, inc/dec offers and EoD linepack bids posted on the market information bulletin board is used for the purposes of scheduling, pricing and settlement in accordance with these Rules.
(e)	If a nomination, an inc/dec offer or an EoD linepack bid is invalid (as determined by VENCorp in accordance with the electronic communication procedures), VENCorp must not schedule that nomination, inc/dec offer or EoD linepack bid and must, as soon as reasonably practicable after it becomes aware of the invalidity of the nomination, inc/dec offer or EoD linepack bid, notify the Market Participant who has submitted the nomination, inc/dec offer or EoD linepack bid of its invalidity.
3.1.10	Other nomination, inc/dec offer and EoD linepack bid requirements
(a)	Market Participants must submit their nominations, inc/dec offers and EoD linepack bids to VENCorp in accordance with the electronic communication procedures, unless otherwise determined by VENCorp.
(b)	A nomination submitted by a Market Participant in respect of a system point for a gas day will be deemed to be revoked by a subsequent nomination submitted by that Market Participant in respect of that same system point and that same gas day.
(c)	An inc/dec offer submitted by a Market Participant in respect of a system point for a gas day will be deemed to be revoked by a subsequent inc/dec offer submitted by that Market Participant in respect of that same system point and that same gas day.
(d)	An EoD linepack bid submitted by a Market Participant in respect of a gas day will be deemed to be revoked by a subsequent EoD linepack bid submitted by that Market Participant in respect of that same gas day.
(e)	A Market Participant may submit, vary and revoke standing nominations, standing inc/dec offers and standing EoD linepack bids, provided that it does so in accordance with the electronic communication procedures.
(f)	Each Market Participant warrants to VENCorp that:
(1)	each injection nomination submitted by that Market Participant will be made in good faith and represent that Market Participant’s best estimate of the quantities of gas which it expects to inject into the transmission system at the relevant system injection point on the relevant gas day and the timing of such injections (unless instructed by VENCorp to do otherwise);
(2)	each withdrawal nomination submitted by that Market Participant will be made in good faith and represent that Market Participant’s best estimate of the quantities of gas which it expects to withdraw from the transmission system at the relevant system withdrawal zone on the relevant gas day and the timing of such withdrawals (unless instructed by VENCorp to do otherwise); and
(3)	if scheduled to do so by VENCorp, it will be able to modify the quantities of gas which it injects into, or withdraws from, the transmission system on a gas day in accordance with the inc/dec offers submitted by that Market Participant in respect of that gas day.
(g)	To avoid doubt, the aggregate quantities of gas (if any) which a Market Participant nominates for injection into the transmission system on a gas day need not be equal to the aggregate quantities of gas (if any) which that Market Participant nominates for withdrawal from the transmission system on that gas day.
(h)	A Market Participant who knows or believes that it will not, or that it is unlikely to be able to, comply in any material respect with the injections or withdrawals scheduled for that Market Participant in a final operating schedule must immediately notify VENCorp of that fact and the extent of the known or likely non‑compliance.
(i)	The acceptance or scheduling of a nomination or an inc/dec offer by VENCorp, or the failure by VENCorp to reject a nomination or an inc/dec offer, will not constitute an offer or undertaking by VENCorp to receive, convey or deliver any quantity of gas.
3.1.11	Priority of inc/dec offers
If the information provided in inc/dec offers implies that two or more inc/dec offers are equally beneficial for scheduling, then VENCorp must schedule those offers in accordance with the following principles:
(a)	an  injection inc/dec offer should be scheduled before a withdrawal inc/dec offer;
(b)	where two or more injection inc/dec offers are equally beneficial, those injection inc/dec offers should be scheduled as far as practicable to the same extent; and
(c)	where two or more withdrawal inc/dec offers are equally beneficial, those withdrawal inc/dec offers should be scheduled as far as practicable to the same extent.
3.1.12	Preliminary and final operating schedules
(a)	VENCorp must use the following inputs and assumptions for the purpose of producing preliminary operating schedules and final operating schedules for a gas day:
(1)	the nominations and inc/dec offers submitted by Market Participants in respect of that gas day, including any  conditions or constraints included in such inc/dec offers in accordance with clause 3.1.5(f);
(2)	VENCorp’s demand projections by location for that gas day including any margin for system security, as determined in accordance with the gas scheduling procedures;
(3)	the linepack required by VENCorp in respect of that gas day;
(4)	any equations or constraints relating to the flow of gas in the transmission system, including without limitation mass, gas flow and minimum and maximum operating pressures;
(5)	in the case of operating schedules produced in respect of a gas day prior to that gas day, the forecast condition of the flow of gas in the transmission system at the start of that gas day, including without limitation mass, operating pressures and quantity and distribution of linepack;
(6)	in the case of final operating schedules produced in respect of a gas day on that gas day, the actual condition of the flow of gas in the transmission system, including without limitation mass, operating pressures and quantity and distribution of linepack;
(7)	the actual or forecast state or condition of the pipelines and pipeline equipment which constitute the transmission system; and
(8)	any other inputs or assumptions specified for that purpose in the gas scheduling procedures.
(b)	The inputs and assumptions set out in clause 3.1.12(a) are to be applied by VENCorp in an optimisation program in which nominations, inc/dec offers and EoD linepack bids submitted by Market Participants are used to produce preliminary operating schedules and final operating schedules which specify injections and withdrawals for each hour of the gas day in a way that minimises the cost of satisfying demand for gas over that gas day taking account of any transmission constraints affecting the transmission or storage of gas in the transmission system during that gas day.
(c)	Each day VENCorp must publish:
(1)	by 1.00 pm, a preliminary operating schedule covering each hour in the gas day starting at 9.00 am on the second day after the current day;
(2)	by 10.00 am, a preliminary operating schedule covering each hour in the gas day starting at 9.00 am on the day after the current day; and
(3)	as soon as reasonably practicable and in any event by 9.00 am, a final operating schedule covering each hour in the gas day starting at 9.00 am on the current day. 
(d)	If, after a preliminary operating schedule or a final operating schedule has been published, a change in circumstances occurs which VENCorp considers is likely to have a material effect on the operation of the transmission system on the gas day in respect of which such schedule is made, VENCorp must publish a further preliminary operating schedule or final operating schedule (as the case may be) in respect of that gas day as soon as reasonably practicable.
(e)	Each preliminary operating schedule and final operating schedule must include the information set out in clause 5.1.4(b). 
(f)	All material factors which VENCorp takes into account for the purposes of preparing a preliminary operating schedule or a final operating schedule must be recorded by VENCorp so that the gas scheduling procedures can be properly audited.
(g)	VENCorp must maintain records relating to the scheduling process undertaken by VENCorp in respect of each gas day and make those records available to any Market Participant, subject to the Market Participant paying the reasonable costs incurred by VENCorp in making those records available.
(h)	VENCorp must issue scheduling instructions to each Market Participant by no later than 9.00 am on each day, specifying the quantities of gas which each Market Participant is scheduled to inject or withdraw for each hour of the gas day commencing at 9.00 am on that day at each injection point and withdrawal zone.
(i)	VENCorp may make changes to the final operating schedule by issuing scheduling instructions during the gas day in accordance with the gas scheduling procedures.
(j)	VENCorp must ensure that all scheduling instructions and the times at which they are issued are automatically logged electronically or otherwise recorded. 
3.1.13	Failure to conform to scheduling instructions
(a)	Subject to clauses 3.1.13(b) and (d), if VENCorp issues a scheduling instruction  in respect of an injection nomination or an inc/dec offer, the Market Participant who submitted the injection nomination or the inc/dec offer must comply with the scheduling instruction in all material respects.
(b)	If a Market Participant is unable to comply in all material respects with a scheduling instruction issued in respect of an injection nomination or an inc/dec offer, it must:
(1)	notify VENCorp that it is unable to comply with the scheduling instruction as soon as practicable after it becomes aware of its failure to comply and give the reasons for the failure; and
(2)	provide VENCorp with such evidence of the reasons for the failure as VENCorp may reasonably require.
(c)	If a Market Participant is unable to comply in all material respects with a scheduling instruction issued in respect of an injection nomination  or an inc/dec offer, VENCorp must notify all Market Participants of that fact and VENCorp must, on request, provide details of the reasons for the failure to comply if and to the extent that those reasons have been provided.
(d)	A Market Participant is not obliged to comply with a scheduling instruction issued in respect of an injection nomination or an  inc/dec offer if it is unable to do so:
(1)	due to a technical fault or failure which, in the opinion of VENCorp, was outside that Market Participant’s control; or
(2)	in the case of an injection nomination or an injection inc/dec offer, because the Market Participant ordered a quantity of gas from a Producer or other person to enable it to comply with that injection nomination or injection inc/dec offer and that Producer or other person was only required, under the terms of its contract with that Market Participant, to use its reasonable endeavours to deliver that quantity of gas and that Producer or other person does not in fact deliver that quantity of gas.
(e)	Subject to clauses 3.1.13(b) and (d), if a Market Participant fails to comply in any material respect (as determined by VENCorp in its reasonable opinion) with a scheduling instruction issued in respect of an injection nomination or an inc/dec offer, then:
(1)	the gas injection or gas withdrawal which is the subject of that scheduling instruction must be declared by VENCorp to be non-conforming; and
(2)	the relevant Market Participant may be liable to pay financial penalties or other sanctions imposed under the Gas Industry Act for breach of these Rules.
(f)	If a gas injection or gas withdrawal which is the subject of a scheduling instruction issued in respect of an injection nomination or an inc/dec offer is declared by VENCorp to be non-conforming in accordance with clause 3.1.13(e):
(1)	VENCorp must notify the relevant Market Participant that the gas injection or gas withdrawal does not conform and request a reason for the Market Participant’s failure to comply with the scheduling instruction; and
(2)	if the relevant Market Participant fails to respond to the request set out in clause 3.1.13(f)(1) or if VENCorp is not satisfied that the relevant Market Participant will respond to any future scheduling instruction, VENCorp may intervene by issuing directions or requiring the Market Participant to take action in accordance with clause 6.6 (which intervention may include requiring the Market Participant to inject or withdraw gas at a constant rate).
(g)	Until a Market Participant responds to a request under clause 3.1.13(f)(1) and VENCorp is satisfied that the Market Participant will respond to future scheduling instructions, the gas injection or gas withdrawal which is the subject of the relevant injection nomination or inc/dec offer will continue to be non-conforming.
3.1.14	Scheduling errors
(a)	If either:
(1)	the dispute resolution panel determines under clause 7.2 that VENCorp has failed to follow the gas scheduling procedures for the purpose of issuing scheduling instructions; or
(2)	VENCorp declares that it has not complied with the gas scheduling procedures for the purpose of issuing scheduling instructions,
a scheduling error will be deemed to have occurred and a Market Participant may be entitled to compensation in accordance with clause  3.3.3. 
(b)	Market prices are not to be adjusted when a scheduling error is deemed to have occurred.
3.1.15	Injection and withdrawal confirmations
(a)	Each Participant who is registered as a Producer or a Storage Provider under clause 2.1(a) must by no later than 4.00 pm on each day notify VENCorp of the total quantity of gas that it intends to inject into, and withdraw from, the transmission system on its own account (if any) and on behalf of Market Participants during the gas day commencing on the following day.
(b)	If, for any reason, there is a material change to the quantity of gas previously notified by a Participant under this clause 3.1.15, then the Participant must promptly notify VENCorp of the change.
3.1.16	Title to gas
(a)	Until such time as title to gas injected by a Market Participant is transferred to another Market Participant or to the Market Participants as owners in common in accordance with clause 3.1.16(b), title to gas injected into the transmission system shall at all times remain with the Market Participant which injected such gas or, if a Market Participant has injected gas, or arranged for gas to be injected, into the transmission system as agent, the principal on whose behalf such gas was injected.
(b)	VENCorp must establish rules for determining ownership of gas in the transmission system and the times and places at which title to gas is transferred between Market Participants as a result of transactions in gas effected in accordance with these Rules.
(c)	In the event of a dispute between Participants relating to the ownership of gas in the transmission system, VENCorp must determine the dispute in accordance with the rules established pursuant to clause 3.1.16(b) and any such determination shall be binding on all Participants.
(d)	Each Market Participant warrants to VENCorp that:
(1)	it will have title to all gas injected into, or tendered for injection into, the transmission system by it at any system injection point or, where the Market Participant is acting as agent in respect of a quantity of gas so injected, it will be unconditionally and irrevocably authorised to transfer title to such gas to such person as VENCorp may determine in accordance with these Rules; and 
(2)	all such gas will (at the system injection point) be free of any lien, charge or encumbrance or adverse claim (as to title or otherwise), including any claim for any tax, royalty or other charge in respect of the production, gathering, processing and tendering of gas arising on or before injection of gas into the transmission system.
(e)	Each Market Participant unconditionally and irrevocably authorises VENCorp to effect any transfer of title to gas injected by it into the transmission system and to determine the time and place of transfer and the quantities of gas transferred in accordance with these Rules.
(f)	Each Market Participant must indemnify VENCorp and hold it harmless against any loss, liability, damage, claim, action, proceeding, cost and expense suffered or incurred by or made or brought against VENCorp in consequence of any breach of the warranties in clause 3.1.16(d).
(g)	VENCorp makes no warranty regarding the merchantability or suitability for any purpose of gas delivered at a system withdrawal point and all implied warranties are excluded to the maximum extent permitted by law.
(h)	Custody and control, and risk of loss, of gas injected into the transmission system at a system injection point shall pass to VENCorp.
(i)	Custody and control, and risk of loss, of gas withdrawn from the transmission system at a system withdrawal point shall pass to the Market Participant who has title to that gas at that system withdrawal point immediately prior to such withdrawal or, where a Market Participant has injected gas as agent for a third party, to the Market Participant whose principal has title to gas at that system withdrawal point immediately prior to such withdrawal.
(j)	VENCorp has the right to co-mingle a Market Participant’s gas with other gas in the transmission system.
(k)	Each Market Participant acknowledges and accepts that the gas delivered to it at a system withdrawal point may not match the specifications of the gas injected, or tendered for injection, into the transmission system by that Market Participant at a system injection point.

3.2	DETERMINATION OF MARKET PRICE

3.2.1	Determination of market price
(a)	The market price for each trading interval and each pricing zone is to be determined by VENCorp in accordance with this clause 3.2.
(b)	After the end of each gas day, VENCorp must produce a pricing schedule in accordance with clause 3.2.1(e) for the purpose of determining the market price for each pricing zone and each trading interval for that gas day.
(c)	VENCorp must use the following inputs for the purpose of producing the pricing schedule for a gas day and for the purpose of doing so, VENCorp  is to assume that there are no transmission constraints affecting the transportation or storage of gas in the transmission system during that gas day:
(1)	valid nominations and valid inc/dec offers submitted by the Market Participant in respect of that gas day;
(2)	the actual market demand (as defined in clause 3.2.1(d)) for each hour of that gas day;
(3)	the actual quantities of gas injected into the transmission system during each hour of that gas day;
(4)	the quantity of EoD linepack purchased by Market Participants in respect of the previous gas day in accordance with clause 3.4.2;
(5)	valid EoD linepack bids submitted by Market Participants in respect of that gas day; and
(6)	EoD linepack capacity,
and any other inputs or assumptions specified for that purpose in the gas scheduling procedures.
(d)	For the purpose of clause 3.2.1(c), the “actual market demand” means, in respect of each hour of the gas day, the sum of:
(1)	the total quantity of gas withdrawn from the transmission system in that hour of the gas day as determined in accordance with clause 4.4 less the total quantity of gas withdrawn in that hour of the gas day at a delivery point in respect of which accreditation has been given by VENCorp under clause 3.1.6 and in respect of which a withdrawal inc/dec offer has been submitted; plus
(2)	the maximum quantity of gas withdrawals specified (whether or not such gas is actually withdrawn) in valid withdrawal inc/dec offers submitted in respect of that hour of the gas day by Market Participants who are accredited by VENCorp under clause 3.1.6; plus
(3)	the amount (which amount may be less than zero) by which the total quantity of gas injected into the transmission system in that hour of the gas day determined in accordance with clause 4.4 is less than the total quantity of gas scheduled to be injected into the transmission system  in accordance with scheduling instructions issued by VENCorp; plus
(4)	the security margin for that gas day as determined in accordance with the gas scheduling procedures.
(e)	The inputs and assumptions set out in clause 3.2.1(c) are to be applied by VENCorp in an optimisation program in which nominations, inc/dec offers and EoD linepack bids submitted by Market Participants are used to produce a pricing schedule which specifies injections and withdrawals of gas to be made in each trading interval and each pricing zone in a way which minimises the cost of satisfying the actual market demand for gas (as defined under clause 3.2.1(d)) in that trading interval and for the purpose of doing so, VENCorp is to assume that there are no transmission constraints affecting the transportation or storage of gas in the transmission system during that gas day.
(f)	The pricing schedule for a gas day will determine:
(1)	the market price for each pricing zone for that gas day;
(2)	the quantity of gas that each Market Participant would have been scheduled to inject and/or withdraw in each hour of the gas day on the basis of the inputs and assumptions applied under clause 3.2.1(c);
(3)	the quantity of EoD linepack (if any) purchased by each Market Participant who submitted an EoD linepack bid in respect of that gas day; and
(4)	the price of EoD linepack capacity for that gas day.
(g)	VENCorp must publish the market price in accordance with clause 5.1.4(e).
3.2.2	Pricing in the event of force majeure event or suspension of the market
(a)	Subject to clause 3.2.2(c), in the event of a force majeure event or if VENCorp has suspended the market under clause 6.7.3, VENCorp must, if and to the extent that VENCorp considers it reasonably possible to do so, use:
(1)	the gas scheduling procedures; and
(2)	the pricing schedule,
to determine the market price in each pricing zone and for each trading interval during which that force majeure event or suspension continues.
(b)	If VENCorp reasonably considers that it is unable to properly determine the market price under clause 3.2.2(a), VENCorp must, subject to clause 3.2.2(c), determine the market price for that trading interval and pricing zone using any other available knowledge and information that VENCorp considers to be relevant and reasonable, including but not limited to any forecast prices most recently published under clause 5.1.4 in relation to that trading interval.  
(c)	If VENCorp determines the market price under clause 3.2.2(a) or (b):
(1)	it must do so in accordance with this clause 3.2, if and to the extent that VENCorp considers it reasonably possible to do so; and
(2)	the market price must not exceed the administered price cap.
3.2.3	Failure of scheduling software/systems
(a)	Subject to clause 3.2.3(c), if:
(1)	there is no force majeure event and/or the market has not been suspended in a trading interval and a pricing zone; and
(2)	VENCorp is unable to determine the market price in respect of that trading interval and pricing zone in accordance with this clause 3.2 as a result of a failure of scheduling software or systems or for any other reason,
VENCorp must, if and to the extent VENCorp considers it reasonably possible to do so, use:
(3)	the gas scheduling procedures; and 
(4)	the pricing schedule,
to determine the market price for that trading interval and that pricing zone in respect of which VENCorp is unable to determine the market price in accordance with this clause 3.2.
(b)	If VENCorp reasonably considers that it is unable to properly determine the market price under clause 3.2.3(a) for a trading interval and pricing zone during which VENCorp is otherwise unable to determine the market price in accordance with this clause 3.2, VENCorp must, subject to clause 3.2.3(c), determine the market price for that trading interval and pricing zone using any other available knowledge and information that VENCorp considers to be relevant and reasonable, including but not limited to any forecast prices most recently published under clause 5.1.4 in relation to that trading interval.
(c)	If VENCorp determines the market price under clause 3.2.3(a) or (b),
(1)	it must do so in accordance with this clause 3.2, if and to the extent that VENCorp considers it reasonably possible to do so; and
(2)	the market price must not exceed the administered price cap.
3.2.4	VoLL
(a)	If hourly injections and withdrawals of gas as determined under clause 3.2.1(f)(2) imply that curtailment would have occurred in a pricing zone in a trading interval (whether or not curtailment actually occurs) the market price for that pricing zone and that trading interval is VoLL.
(b)	Subject to clause 3.2.4(e), the value of VoLL is $800/GJ.
(c)	Within twelve months of the commencement date, VENCorp must conduct a review of the value of VoLL in accordance with the public consultation procedures.
(d)	After the initial review of VoLL referred to in clause 3.2.4(c), VENCorp must undertake a review of VoLL in accordance with this clause 3.2.4 at intervals not exceeding two years.
(e)	If VENCorp determines that the value of VoLL should be changed as a result of the reviews referred to in clauses 3.2.4(c) and (d), VENCorp must propose that the value of VoLL be changed in accordance with the rule change procedures in chapter 8.
(f)	Any change to the value of VoLL must take effect within six months of the date on which the notice of the change is published in accordance with clause 8.8(b).
3.2.5	Transition to hourly locational pricing
With effect from 1 December 2000, these Rules are to be amended, as necessary in accordance with clause 9.1.1, to change from daily pricing using one pricing zone to hourly, locational pricing.

3.3	Participant Compensation Fund

3.3.1	Establishment of the participant compensation fund
VENCorp must establish and maintain a fund to be called the participant compensation fund for the purpose of paying compensation to Market Participants for scheduling errors as determined by the dispute resolution panel.
3.3.2	Funding the participant compensation fund
(a)	Each year VENCorp must collect from each Market Participant, and each Market Participant must pay to VENCorp, an amount calculated in accordance with clause 3.3.2(d).
(b)	Subject to clause 3.3.2(c), the funding requirement for the participant compensation fund for each financial year until 30 June 2001 is the lesser of:
(1)	$500,000; and
(2)	$2,000,000 minus the amount which VENCorp reasonably considers will be the balance of the participant compensation fund at the end of the relevant financial year.
(c)	The amount of the funding requirement referred to in clause 3.3.2(b):
(1)	can be varied from time to time by VENCorp in consultation with Market Participants and with the prior written consent of the Regulator; and
(2)	must be reviewed by VENCorp prior to 30 June 2001 to determine whether it has been set at an appropriate level, taking into consideration the amount of compensation paid from it in each financial year and any change to the amount of the funding requirement which results from that review must take effect from 1 July 2001.
(d)	VENCorp must, no later than the date of issue of the first preliminary settlement statement in each financial year calculate a contribution rate for contributions to the participant compensation fund which is to apply for that financial year by dividing the funding requirement determined in accordance with clause 3.3.2(b) by VENCorp’s reasonable forecast of the aggregate quantity of gas which it expects all Market Participants will withdraw from the transmission system for the relevant financial year.
(e)	VENCorp must, no later than the date of issue of the first preliminary settlement statement in each financial year, publish the funding requirement determined in accordance with clause 3.3.2(b), the contribution rate determined in accordance with clause 3.3.2(d), and the basis on which that funding requirement and that contribution rate have been determined.
(f)	Each Market Participant must pay as part of the settlement amount payable by that Market Participant in respect of each settlement period, an amount calculated by multiplying the contribution rate determined in accordance with clause 3.3.2(d) by the aggregate quantity of gas withdrawn from the transmission system by that Market Participant during the relevant settlement period as determined from metering data in accordance with clause 4.4.
(g)	The component of the settlement amount payable by a Market Participant in respect of the participant compensation fund must be paid into the participant compensation fund. 
(h)	Participants will not be entitled to a refund of any contributions made to the participant compensation fund.
(i)	The participant compensation fund is to be maintained by VENCorp and is the property of VENCorp.
(j)	Any interest paid on money held in the participant compensation fund will accrue to and form part of the participant compensation fund.
(k)	VENCorp will pay from the participant compensation fund: 
(1)	all income tax on interest earned by the participant compensation fund;  
(2)	all bank account debit tax, financial institutions duty and bank fees in relation to the participant compensation fund; and 
(3)	compensation to Market Participants in accordance with clause 3.3.3.
3.3.3	Dispute Resolution Panel to determine compensation
If a scheduling error has occurred, the dispute resolution panel must determine, subject to clause 3.3.4:
(a)	which Market Participants are to receive compensation from the participant compensation fund in respect of that scheduling error; and 
(b)	the amount of compensation each Market Participant is to receive.
3.3.4	Compensation limited
The aggregate amount of compensation paid each year from the participant compensation fund must not exceed the balance of the participant compensation fund that would have been available at the end of that year had no compensation payments been made that year and therefore the dispute resolution panel must, when making a determination, take into account: 
(a)	the balance of the participant compensation fund at the time the determination is being made; and 
(b)	the possibility that further compensation payments will be required to be made during that year. 
3.3.5	Manner and timing of compensation payments
The manner and timing of payments from the participant compensation fund will be determined by the dispute resolution panel.
3.3.6	VENCorp and its officers not liable
Neither VENCorp nor its officers are liable in respect of a scheduling error, except out of the participant compensation fund as contemplated under this clause 3.3.

3.4	EoD LINEPACK

3.4.1	Purpose of this clause
This clause 3.4 sets out the basis on which:
(a)	a Market Participant may bid for EoD linepack; and
(b)	a Market Participant who purchases EoD linepack will receive daily EoD linepack credits or daily EoD linepack debits in respect of purchases and sales of EoD linepack. 
3.4.2	Purchase of EoD linepack and determination of the price of EoD linepack and the price of EoD linepack capacity 
(a)	A Market Participant may offer to purchase EoD linepack on a gas day by submitting an EoD linepack bid to VENCorp in respect of that gas day in accordance with clause 3.1.8.
(b)	Subject to clauses 3.4.2(c) to (h), VENCorp must allocate EoD linepack pursuant to EoD linepack bids and determine the price for EoD linepack and the price of EoD linepack capacity in respect of each gas day in accordance with the gas scheduling procedures and the pricing schedule.
(c)	Only Market Participants whose EoD linepack bids in respect of a gas day specify prices equal to or greater than the market price for that gas day will be allocated any EoD linepack.
(d)	The aggregate amount of EoD linepack allocated to Market Participants in respect of a gas day must not exceed the EoD linepack capacity.
(e)	If the amount of EoD linepack bid for in respect of a gas day at a price equal to or greater than the market price for that gas day exceeds the EoD linepack capacity, the price of EoD linepack for that gas day will be determined by VENCorp, in accordance with gas scheduling procedures, as the price necessary to ensure that the amount of EoD linepack allocated in respect of that gas day is equal to the EoD linepack capacity. 
(f)	The price of EoD linepack capacity on a gas day is equal to the price of EoD linepack on that gas day as determined by VENCorp in accordance with this clause 3.4.2 less the market price for that gas day.
(g)	If the amount of EoD linepack allocated in respect of a gas day is less than the amount of the EoD linepack capacity, the price of EoD linepack capacity on that gas day is zero.
(h)	VENCorp must notify each Market Participant who has submitted an EoD linepack bid in respect of a gas day as soon as reasonably practicable after the end of that gas day of the quantity of EoD linepack (if any) allocated to that Market Participant and the EoD linepack price .
3.4.3	Effect of acceptance of EoD linepack bids
(a)	Where EoD linepack is allocated to a Market Participant in respect of a gas day (referred to in this clause as the “current gas day”) in accordance with clause 3.4.2:
(1)	the quantity of EoD linepack allocated is deemed to have been purchased by that Market Participant on the current gas day at the price of EoD linepack for the current gas day;
(2)	the quantity of EoD linepack allocated to that Market Participant (if any) in respect of the immediately preceding gas day is deemed to be sold by the Market Participant on the current gas day at the market price for the current gas day; and
(3)	such deemed purchases and sales are to be taken into account in determining that Market Participant’s daily EoD linepack credits or daily EoD linepack debits.
(b)	Save as set out in this clause 3.4.3, the acceptance by VENCorp of a Market Participant’s EoD linepack bid and the allocation of EoD linepack to a Market Participant does not confer any rights or privileges on the Market Participant, nor does it confer on the Market Participant any right, title or interest in or to any gas.
3.4.4	Determination of EoD linepack capacity
(a)	Prior to the commencement date, VENCorp must:
(1)	determine the total amount of EoD linepack capacity which must be made available to Market Participants on the commencement date; and
(2)	publish the total amount of EoD linepack capacity determined by it pursuant to this clause 3.4.4 and the basis of its determination.
(b)	If, at any time after the commencement date, VENCorp considers that there has been a material change in the amount of EoD linepack capacity, VENCorp must determine and publish the amount of EoD linepack capacity and the basis of its determination.

3.5	ALLOCATION AND RECONCILIATION

3.5.1	Daily quantities
For the purposes of these Rules, including determining:
(a)	trading imbalances under clause 3.6.4; and
(b)	market fees under clause 2.6,
the quantity of gas treated as injected into and withdrawn from the transmission system by each Market Participant each gas day shall be determined in accordance with this clause 3.5.
3.5.2	Injection allocations
(a)	Where gas is injected, or tendered for injection, at a system injection point by more than one Market Participant, the Market Participants who inject gas, or tender gas for injection, at that system injection point must together appoint a single Allocation Agent to determine the quantity of gas which is to be treated as injected into the transmission system by each of those Market Participants from time to time at that system injection point.
(b)	Unless otherwise agreed by VENCorp, a Market Participant must not submit nominations or inc/dec offers in respect of a system injection point to which clause 3.5.2(a) applies or inject, or tender for injection, gas at a system injection point to which clause 3.5.2(a) applies unless:
(1)	that Market Participant has appointed the Allocation Agent for that system injection point for the purpose described in clause 3.5.2(a); and
(2)	the Allocation Agent for that system injection point has confirmed to VENCorp that it has been appointed by that Market Participant for the purpose described in clause 3.5.2(a),
provided that, notwithstanding any other provision of this clause 3.5, if an Allocation Agent has not been appointed by a Market Participant for a system injection point or such an Allocation Agent has ceased to act in respect of that system injection point for any reason whatsoever, VENCorp may, with the approval of the Regulator, appoint an Allocation Agent for that system injection point and such an appointment shall be deemed to be that of that Market Participant.
(c)	Only one Allocation Agent shall be appointed for each system injection point.
(d)	Each Market Participant must immediately notify VENCorp if an Allocation Agent ceases to be appointed by it in relation to any system injection point.
(e)	Each Market Participant who appoints an Allocation Agent must for the term of that appointment ensure that such Allocation Agent complies with the provisions of this clause 3.5. 
(f)	If an Allocation Agent does not comply with the provisions of this clause 3.5, VENCorp is not required to have regard to any injection allocation statement submitted by that Allocation Agent and clause 3.5.2(m) will apply for the purpose of allocation.
(g)	Each Allocation Agent must, in respect of each system injection point in relation to which it has been appointed, give to VENCorp, not later than the third day after each gas day or such later time as VENCorp may agree with that Allocation Agent, a statement in respect of that gas day specifying:
(1)	the identity of the system injection point;
(2)	the gas day to which the statement relates;
(3)	the identity of each Market Participant which injected gas into the transmission system at that system injection point on that gas day; 
(4)	the total quantity of gas injected into the transmission system at that system injection point during each trading interval on that gas day; and
(5)	the quantity of gas which is to be treated as injected by each Market Participant into the transmission system at that system injection point on each trading interval during that gas day.
(h)	The total quantity of gas allocated by each Allocation Agent in respect of a trading interval at a system injection point must equal the total quantity of gas injected into the transmission system during that trading interval at that system injection point (as measured and determined in accordance with clause 4.4).
(i)	Where an injection allocation statement has been submitted by an Allocation Agent which specifies a Market Participant as having injected a quantity of gas into the transmission system at a system injection point on a gas day, that Market Participant may submit to VENCorp, not later than the third day after that gas day or such later time as VENCorp may agree with that Market Participant, a sub-allocation statement specifying:
(1)	that such quantity is to be treated as having been injected into the transmission system at that system injection point by one or more Market Participants (who may include the Market Participant specified in the injection allocation statement);
(2)	the identity of those Market Participants;
(3)	the gas day to which the statement relates; and
(4)	the quantity which is to be treated as having been injected by each of those Market Participants.
(j)	VENCorp is not required to have regard to any sub-allocation statement unless each Market Participant identified in that sub-allocation statement has confirmed in writing to VENCorp that it has appointed the Sub-allocation Agent for the relevant system injection point for the purposes of clause 3.5.2(i).
(k)	VENCorp is entitled to rely on any injection allocation statement or sub-allocation statement which has been submitted by an Allocation Agent or a Sub-allocation Agent for the purposes of determining the quantities of gas treated as injected into the transmission system by all Market Participants who have appointed that Allocation Agent or Sub-allocation Agent.
(l)	If:
(1)	an Allocation Agent has not been appointed in respect of a system injection point; or
(2)	VENCorp is notified by a Market Participant that the appointment of an Allocation Agent in respect of a system injection point has been terminated by that or any other Market Participant,
VENCorp must determine the quantities of gas which are to be treated as injected by Market Participants at that system injection point in accordance with clause 3.5.2(m) and, in the case of paragraph (2) of this clause 3.5.2(l), must disregard any injection allocation statement subsequently given by that Allocation Agent in respect of that system injection point.
(m)	If clauses 3.5.2(f) or (l) apply, VENCorp must determine the quantity of gas which is to be treated as having been injected by each Market Participant at the relevant system injection point in accordance with the following formula:
Q   =   MQ   x   
Where:
Q	is the quantity of gas which is to be treated as having been injected by that Market Participant at that system injection point in a trading interval;
MQ	is the actual quantity of gas injected into the transmission system at that system injection point in that trading interval;
SQi	is the quantity of gas scheduled by VENCorp for injection by that Market Participant at that system injection point in that trading interval; and
SQj	is the total quantity of gas scheduled by VENCorp for injection by all Market Participants at that system injection point in that trading interval,
provided that VENCorp may, with the approval of the Regulator and on prior notice given to any affected Market Participant, vary the above formula, or use a different formula, in any case where it is established that the application of the above formula, in all the circumstances, affords undue preference to that Market Participant and undue prejudice to other Market Participants and in exercising its discretion under this proviso, VENCorp may, with the approval of the Regulator, have regard to title to gas.
(n)	An Allocation Agent may be appointed to act in relation to more than one system injection point and may also be appointed to act in relation to one or more system withdrawal points.
3.5.3	Withdrawal allocations - non-SAW points
(a)	Where gas is withdrawn, or tendered for withdrawal, at a non-SAW point by more than one Market Participant and there are insufficient metering installations installed to enable VENCorp to determine the quantity of gas withdrawn at that non-SAW point by each Market Participant, the Market Participants who withdraw gas, or tender gas for withdrawal, at that non-SAW point must together appoint a single Allocation Agent to determine the quantity of gas which is to be treated as withdrawn from the transmission system by each of those Market Participants from time to time at that non-SAW point.
(b)	Unless otherwise agreed by VENCorp, a Market Participant must not submit nominations or inc/dec offers in respect of a non-SAW point to which clause 3.5.3(a) applies or withdraw, or tender for withdrawal, gas at a non-SAW point to which clause 3.5.3(a) applies unless:
(1)	that Market Participant has appointed the Allocation Agent for that non-SAW point for the purpose described in clause 3.5.3(a); and
(2)	the Allocation Agent for that non-SAW point has confirmed to VENCorp that it has been appointed by that Market Participant for the purpose described in clause 3.5.3(a).
(c)	Only one Allocation Agent shall be appointed for each non-SAW point.
(d)	Each Market Participant must immediately notify VENCorp if an Allocation Agent ceases to be appointed by it in relation to any non-SAW point.
(e)	Each Market Participant who appoints an Allocation Agent must ensure for the term of the appointment that such Allocation Agent complies with the provisions of this clause 3.5. 
(f)	If an Allocation Agent does not comply with the provisions of this clause 3.5, VENCorp is not required to have regard to any withdrawal allocation statement submitted by that Allocation Agent and clause 3.5.3(m) will apply for the purpose of determining allocations.
(g)	Each Allocation Agent must, in respect of each non-SAW point in respect of which it has been appointed, give to VENCorp, not later than the third day after each gas day or such later time as VENCorp may agree with that Allocation Agent, a statement in respect of that gas day specifying:
(1)	the identity of the non-SAW point;
(2)	the gas day to which the statement relates;
(3)	the identity of each Market Participant which withdraws gas from the transmission system at that non-SAW point on that gas day; 
(4)	the total quantity of gas withdrawn from the transmission system at that non-SAW point during each trading interval on that gas day; and
(5)	the quantity of gas which is to be treated as withdrawn by each Market Participant from the transmission system at that non-SAW point on each trading interval during that gas day.
(h)	The total quantity of gas allocated by each Allocation Agent in respect of a trading interval at a non-SAW point must equal the total quantity of gas withdrawn from the transmission system during that trading interval at that non-SAW point (as measured and determined in accordance with clause 4.4).
(i)	Where a withdrawal allocation statement has been submitted by an Allocation Agent which specifies a Market Participant as having withdrawn a quantity of gas from the transmission system at a non-SAW point on a gas day, that Market Participant may submit to VENCorp, not later than the third day after each gas day or such later time as VENCorp may agree with that Market Participant, a sub-allocation statement specifying:
(1)	that such quantity is to be treated as having been withdrawn from the transmission system at that non-SAW point by one or more Market Participants (who may include the Market Participant specified in the withdrawal allocation statement);
(2)	the identity of those Market Participants;
(3)	the gas day to which the statement relates; and
(4)	the proportion of such quantity which is to be treated as having been withdrawn by each of those Market Participants.
(j)	VENCorp is not required to have regard to any sub-allocation statement unless each Market Participant identified in that sub-allocation statement has confirmed in writing to VENCorp that it has appointed the Sub-allocation Agent for the relevant non-SAW point for the purposes of clause 3.5.3(i).
(k)	VENCorp is entitled to rely on any withdrawal allocation statement or sub-allocation statement which has been submitted by an Allocation Agent or a Sub-allocation Agent for the purposes of determining the quantities of gas treated as withdrawn from the transmission system by all Market Participants who have appointed that Allocation Agent or Sub-allocation Agent.
(l)	If:
(1)	an Allocation Agent has not been appointed in respect of a non-SAW point; or
(2)	VENCorp is notified by a Market Participant that the appointment of an Allocation Agent in respect of a non-SAW point has been terminated by that or any other Market Participant,
VENCorp must determine the quantities of gas which are to be treated as withdrawn by Market Participants at that non-SAW point in accordance with clause 3.5.3(m) and, in the case of paragraph (2) of this clause 3.5.3(l), must disregard any withdrawal allocation statement subsequently given by that Allocation Agent in respect of that non-SAW point.
(m)	If clauses 3.5.3(f) or (l) apply, VENCorp must determine the quantity of gas which is to be treated as having been withdrawn by each Market Participant at the relevant non-SAW point in accordance with the following formula:
Q   =   MQ   x   
Where:
Q	is the quantity of gas which is to be treated as having been withdrawn by that Market Participant at that non-SAW point in a trading interval;
MQ	is the actual quantity of gas withdrawn from the transmission system at that non-SAW point in that trading interval;
SQi	is the quantity of gas scheduled by VENCorp for withdrawal by that Market Participant at that non-SAW point in that trading interval; and
SQj	is the total quantity of gas scheduled by VENCorp for withdrawal by all Market Participants at that non-SAW point in that trading interval,
provided that VENCorp may, with the approval of the Regulator and on prior notice given to any affected Market Participant, vary the above formula, or use a different formula, in any case where it is established that the application of the above formula, in all the circumstances, affords undue preference to that Market Participant and undue prejudice to other Market Participants and in exercising its discretion under this proviso, VENCorp may, with the approval of the Regulator, have regard to title to gas.
(n)	An Allocation Agent may be appointed to act in relation to more than one non-SAW point and may also be appointed to act in relation to one or more system injection points.
3.5.4	Withdrawal allocations - SAW points
(a)	VENCorp must establish prior to the commencement date an algorithm for the purpose of allocating the aggregate quantities of gas withdrawn by Market Participants from each SAW point to those Market Participants.
(b)	VENCorp may appoint any expert or adviser for the purpose of assisting in the development of the allocation algorithm.
(c)	VENCorp must, upon request, give a copy of the allocation algorithm to each Market Participant who, in VENCorp’s reasonable opinion, will or is likely to be affected by the allocation algorithm.
(d)	VENCorp must:
(1)	at any time VENCorp considers that the allocation algorithm does not effect an allocation in respect of gas withdrawn from the transmission system at each SAW point in a fair and reasonable way; or
(2)	if VENCorp proposes to designate a system withdrawal point as a new SAW point; or
(3)	upon written request by two or more Participants who, in VENCorp’s reasonable opinion, are affected by the allocation algorithm; and
(4)	in any event, at least once each year,
undertake a review of the allocation algorithm and consult with all Market Participants who, in VENCorp’s reasonable opinion, are affected by the allocation algorithm with a view to making any changes to the allocation algorithm which VENCorp considers necessary to effect a fair and reasonable allocation.
3.5.5	Reconciliation
(a)	VENCorp must establish, prior to the commencement date, reconciliation procedures for the purpose of carrying out a reconciliation and adjustment in respect of gas withdrawn from the transmission system at each SAW point, in respect of the differences between:
(1)	the quantities determined as withdrawn by a Market Participant by application of the allocation algorithm in accordance with clause 3.5.4; and
(2)	the quantities subsequently determined to have been withdrawn by that Market Participant upon the obtaining of NDM meter readings.
(b)	The reconciliation procedures will be used to determine reconciliation amounts for each billing period.
(c)	VENCorp must consult with all Market Participants who, in VENCorp’s reasonable opinion, will or are likely to be affected by the reconciliation procedures with the intent of facilitating the agreement of all such Market Participants to the terms of the reconciliation procedures.
(d)	VENCorp may appoint any expert or adviser for the purpose of assisting in the development of the reconciliation procedures.
(e)	VENCorp must, upon request, give a copy of the reconciliation procedures to each Market Participant who, in VENCorp’s reasonable opinion, will or is likely to be affected by the reconciliation procedures.
(f)	VENCorp must:
(1)	at any time VENCorp considers that the reconciliation procedures do not effect a reconciliation and adjustment in respect of gas withdrawn from the transmission system at each SAW point in a fair way; or
(2)	if VENCorp proposes to designate a system withdrawal point as a new SAW point; or
(3)	upon written request by two or more Participants who, in VENCorp’s reasonable opinion, are affected by the reconciliation procedures; and
(4)	in any event, at least once each calendar year,
undertake a review of the reconciliation procedures and consult with all Market Participants who, in VENCorp’s reasonable opinion, are affected by the reconciliation procedures with a view to:
(5)	making any changes to the reconciliation procedures which VENCorp considers necessary to effect a fair reconciliation and adjustment; and
(6)	facilitating the agreement of all such Market Participants to the changes to the reconciliation procedures.
(g)	Market Participants must comply with the reconciliation procedures.

3.6    SETTLEMENTS

3.6.1	Settlements management by VENCorp
(a)	VENCorp must determine market fees payable by Market Participants and facilitate the billing and settlement of transactions between Market Participants under these Rules in accordance with this clause 3.6.
(b)	Market Participants must pay market fees to VENCorp in accordance with clause 2.6.
3.6.2	Electronic funds transfer
(a)	VENCorp must ensure that an EFT facility is provided and made available for all Market Participants for the purposes of facilitating settlements and the collection and payment of all market fees. 
(b)	Unless otherwise authorised by VENCorp, all Market Participants must use the EFT facility provided by VENCorp under clause 3.6.2(a) for the settlement of transactions and the payment of market fees. 
3.6.3	Trading amounts for trading intervals
(a)	VENCorp must determine for each trading interval:
(1)	each Market Participant’s trading imbalance for that trading interval in accordance with clause 3.6.4;
(2)	each Market Participant’s daily EoD linepack credit or daily EoD linepack debit for that trading interval in accordance with clause 3.6.9;
(3)	the ancillary payment (if any) payable to each Market Participant in respect of that trading interval in accordance with clause 3.6.7;
(4)	the uplift payment (if any) payable by each Market Participant in respect of that trading interval in accordance with clause 3.6.8;
(5)	the market price for that trading interval in accordance with clause 3.2; and
(6)	the trading amount for each Market Participant for that trading interval, as determined in accordance with clause 3.6.3(b).
(b)	The trading amount for a Market Participant for a trading interval equals the sum of:
(1)	that Market Participant’s trading imbalance for that trading interval (determined in accordance with clause 3.6.4) multiplied by the market price for that trading interval; plus
(2)	that Market Participant’s daily EoD linepack credit (if any) for that trading interval determined in accordance with clause 3.6.9; minus
(3)	that Market Participant’s daily EoD linepack debit (if any) for that trading interval determined in accordance with clause 3.6.9.
3.6.4	Trading imbalances
(a)	The trading imbalance of a Market Participant in a trading interval shall be determined, in GJ, as the difference between its aggregate injections of gas at all system injection points in that trading interval and its aggregate adjusted withdrawals of gas, as determined in accordance with clauses 3.6.4(b), (c) and (d) in that trading interval.
(b)	For the purpose of determining each Market Participant’s trading imbalance in a trading interval, VENCorp must make an adjustment to the total quantity of gas (if any) withdrawn by that Market Participant from the transmission system in that trading interval to account for unaccounted for gas in accordance with the following formula:
AW   =   MW / (1 - UAFGT)
Where:
AW	is the adjusted quantity of gas which is to be treated as having been withdrawn by that Market Participant from the transmission system in that trading interval;
MW	is the quantity of gas withdrawn by that Market Participant from the transmission system in that trading interval; and
UAFGT	is 0.0.
(c)	For the purpose of determining each Market Participant’s trading imbalance in a trading interval, VENCorp must make an adjustment to the total quantity of gas (if any) withdrawn by that Market Participant from a distribution delivery point in that trading interval to account for unaccounted for gas in accordance with the following formula:
AW   =   MW / {(1 - UAFGD) x (1-UAFGT)}
Where:
AW	is the adjusted quantity of gas which is to be treated as having been withdrawn by that Market Participant from that distribution delivery point in that trading interval;
MW	is the quantity of gas withdrawn by that Market Participant from that distribution delivery point in that trading interval;
UAFGD	is the relevant value assigned to:
(1)	the Distributor on whose distribution pipeline the distribution delivery point is located; and
(2)	the quantity of gas withdrawn by that Market Participant at that distribution delivery point,
in accordance with Part C of Schedule 1 of the Distribution System Code; and
UAFGT	is 0.0.
(d)	A Market Participant’s adjusted withdrawals at a system withdrawal point or a distribution delivery point are to be determined: 
(1)	at a SAW point, or a non-SAW point at which an Allocation Agent has been appointed in accordance with clause 3.5.3(a), as the quantity of gas allocated to that Market Participant at that system withdrawal point in accordance with clause 3.5.3 or 3.5.4, as appropriate, adjusted in accordance with clause 3.6.4(b); 
(2)	at a non-SAW point at which an Allocation Agent has not been appointed under clause 3.5.3(a), as the metered quantity of gas withdrawn at that system withdrawal point, adjusted in accordance with clause 3.6.4(b), minus the sum of any metered quantities withdrawn at distribution delivery points supplied from that system withdrawal point, adjusted in accordance with clause 3.6.4(c), where gas is withdrawn by Customers other than that Market Participant or that Market Participant’s Customers; and 
(3)	at a distribution delivery point, as the metered quantity of gas withdrawn at that distribution delivery point, adjusted in accordance with clause 3.6.4(c). 
(e)	A Market Participant’s aggregate adjusted withdrawals in a trading interval are determined as: 
AW		=	AWT	       +	AWD
Where:
AW	is the aggregate of all that Market Participant’s adjusted withdrawals in that trading interval; 
AWT	is the sum of all that Market Participants’ adjusted withdrawals at system withdrawal points in that trading interval; and 
AWD	is the sum of all that Market Participant’s adjusted withdrawals in that trading interval at distribution delivery points supplied from system withdrawal points other than those for which quantities have been included in AWT.
3.6.5	Settlement amounts for billing periods
(a)	VENCorp must determine the settlement amount for each Market Participant for each billing period in accordance with clause 3.6.5(b).
(b)	The settlement amount for a Market Participant for a billing period equals the sum of:
(1)	the sum of that Market Participant’s trading amounts for each trading interval in that billing period; plus
(2)	that Market Participant’s positive reconciliation amount (if any) in respect of any prior billing period determined in accordance with clause 3.5; less
(3)	that Market Participant’s negative reconciliation amount (if any) in respect of any prior billing period determined in accordance with clause 3.5; less
(4)	the aggregate of:
(A)	any market fees which that Market Participant is required to pay in respect of that billing period calculated in accordance with clause 2.6; and
(B)	any participant compensation fund contribution which that Market Participant is required to make in accordance with clause 3.3; and
(C)	any amount which that Market Participant is required to pay to VENCorp in respect of compensation payments in accordance with clause 3.6.6; plus
(5)	if VENCorp has completed its determination of ancillary payments and consequential associated uplift payments arising from a trading interval:
(A)	the amount of any ancillary payments determined to be payable to that Market Participant in accordance with clause 3.6.7 in respect of that trading interval and not previously taken into account in determining the settlement amount for a billing period in respect of that Market Participant, minus
(B)	the amount of any uplift payments determined to be payable by that Market Participant in accordance with clause 3.6.8 in respect of that trading interval and not previously taken into account in determining the settlement amount for a billing period in respect of that Market Participant; minus
(6)	any other amounts payable by that Market Participant to VENCorp in respect of that billing period; plus
(7)	any amount payable by VENCorp to that Market Participant in respect of any linepack account surplus in accordance with clause 3.6.12(c); minus
(8)	any amount payable by that Market Participant to VENCorp in respect of any linepack account deficit in accordance with clause 3.6.12(b); plus
(9)	any other amount payable by VENCorp to that Market Participant in respect of that billing period.
(c)	The settlement amount determined by VENCorp pursuant to clause 3.6.5(b) for each Market Participant will be a positive or negative dollar amount.
3.6.6	Compensation payments
(a)	If the compensation panel determines that compensation should be paid to a Market Participant in accordance with clauses 6.6.5 or 6.7.6, each Market Participant who purchased gas from the market in the trading interval or trading intervals in respect of which the market price was affected by the imposition of an administered price cap or in respect of which such compensation has been determined must pay to VENCorp an amount determined in accordance with clause 3.6.6(b).
(b)	VENCorp must determine, in respect of each trading interval referred to in clause 3.6.6(a), the amount payable by each Market Participant who has a negative trading imbalance in such trading interval as follows:
APC  x  Gi
    Gj
where
APC	is the amount of the compensation payment payable to a Market Participant in respect of that trading interval under clauses 6.6.5 or 6.7.6;
Gi	is the negative trading imbalance of that Market Participant in that trading interval; and
Gj 	is the sum of all negative trading imbalances of all Market Participants in that trading interval.
(c)	Any amount which VENCorp determines is payable by a Market Participant in accordance with this clause 3.6.6 may, if the Board of Directors of VENCorp so determines, be paid in instalments or deferred for a specified period of time. If the Board of Directors of VENCorp does not so determine, the whole of such amount must be included by VENCorp in the Market Participant’s next settlement statement.
(d)	Subject to clause 3.6.6(c), VENCorp must include in each settlement statement separate details of any amount payable by a Market Participant as determined in accordance with this clause 3.6.6.
3.6.7	Ancillary payments
(a)	Any Market Participant who, as a result of responding in whole or in part to a scheduling instruction, earns less consumer surplus or supplier surplus (as the case may be) over the gas day than that Market Participant would have earned if it had operated according to the pricing schedule, will receive from VENCorp an ancillary payment equal to that difference as determined in accordance with this clause 3.6.7.
(b)	If, for an hour of the gas day, a Market Participant’s actual deviation and scheduled deviation are both positive or are both negative and the actual deviation does not exceed the scheduled deviation, the ancillary payment for that Market Participant will be:
(1)	the supplier surplus or consumer surplus (as the case may be) determined by reference to the pricing schedule; less
(2)	the supplier surplus or consumer surplus (as the case may be) determined by reference to the actual injections or withdrawals of gas (as the case may be) made by that Market Participant.
(c)	If, for an hour of the gas day, a Market Participant’s actual deviation and scheduled deviation are both positive or are both negative and the actual deviation equals or exceeds the scheduled deviation, the ancillary payment for that Market Participant will be:
(1)	the supplier surplus or consumer surplus (as the case may be) determined by reference to the pricing schedule; less
(2)	the supplier surplus or consumer surplus (as the case may be) determined by reference to the Market Participant’s scheduled injections or withdrawals (as the case may be).
(d)	If, for an hour of the gas day, a Market Participant’s: 
(1)	actual deviation is positive and its scheduled deviation is negative; or
(2)	actual deviation is negative and its scheduled deviation is positive,
the ancillary payment for that Market Participant will be zero.
(e)	The ancillary payment payable to a Market Participant for the gas day is equal to the sum of the ancillary payments for each hour of the gas day determined in accordance with clauses 3.6.7(b), (c) and (d).
(f)	Subject to clause 3.6.7(g), for the purposes of determining the amount of an ancillary payment to be made to a Market Participant, any curtailment of a Market Participant’s withdrawals of gas is to be deemed to be effected pursuant to a withdrawal inc/dec offer the price of which is VoLL unless there is a force majeure event or the market has been suspended, in which case any curtailment of a Market Customer’s withdrawals of gas or any scheduled inc/dec offer is deemed to be effected pursuant to an inc/dec offer, the price of which (in the case of a curtailment) is equal to the administered price cap or (in the case of a scheduled inc/dec offer) is capped at the administered price cap.
(g)	In the event of curtailment, other than curtailment of Customers’ withdrawals in respect of which authorised MDQ has been allocated under clause 5.3.2(a)(1) or clause 5.3.4(a), 
(1)	a Market Customer whose withdrawal of gas is curtailed under clause 6.6.4 will be entitled to be paid an ancillary payment under clause 3.6.7(f) determined as either: 
(A)	the lesser of: 
(i)	that Market Customer’s authorised MDQ minus its actual withdrawal; and 
(ii)	the quantity curtailed; or 
(B)	if that Market Customer’s actual withdrawal is greater than its authorised MDQ, zero; 
(2)	a Retailer whose Customers’ withdrawals of gas are curtailed under clause 6.6.4 will be entitled to be paid an ancillary payment under clause 3.6.7(f) in respect of each of those Customers determined as either: 
(A)	the lesser of: 
(i)	that Customer’s authorised MDQ minus its actual withdrawal; and 
(ii)	the quantity curtailed; or 
(B)	if that Customer’s actual withdrawal is greater than its authorised MDQ, zero. 
(h)	A Market Participant who submits withdrawal inc/dec offers that are not accredited by VENCorp under clause 3.1.6 is not entitled to be paid ancillary payments in respect of those withdrawal inc/dec offers.
3.6.8	Uplift Payments
(a)	Subject to clause 3.6.8(b), VENCorp must consult with Market Participants and establish and publish principles and procedures pursuant to which it can determine an estimate of the portion (if any) of any ancillary payments payable in respect of a trading interval in accordance with clause 3.6.7 which are attributable to transmission constraints.
(b)	In developing the principles and procedures for determining ancillary payments attributable to transmission constraints under clause 3.6.8(a), VENCorp must use its reasonable endeavours to ensure that:
(1)	the principles and procedures should not be unreasonably complex; and 
(2)	any increase in VENCorp’s systems and/or operational costs arising from application of the principles and procedures should not be disproportionate to the aggregate amounts of ancillary payments likely to be made. 
(c)	A Retailer who sells gas to Customers is liable to pay uplift payments in respect of withdrawals of gas by those Customers.
(d)	For the avoidance of doubt, nothing in clause 3.6.8(c) precludes a Retailer from recovering from its Customers the amount of any liability to pay uplift payments in respect of withdrawals of gas by those Customers.
(e)	As soon as reasonably practicable, VENCorp must publish details of total amounts of ancillary payments to be made in respect of each trading interval and the portions of those ancillary payments which are due to transmission constraints, if any.
(f)	If, in accordance with the principles and procedures published by VENCorp under clause 3.6.8(a), VENCorp determines that any part of any ancillary payments which are payable in respect of a trading interval is attributable to a transmission constraint, then VENCorp must also determine and publish:
(1)	after following any procedures for doing so and taking into consideration any other relevant matter set out in the relevant service envelope agreement, the extent (measured in GJ) to which that transmission constraint was caused by the failure of the relevant Transmission Pipeline Owner to fulfil its obligations under its service envelope agreement in that trading interval;
(2)	the extent to which the capacity of the relevant pipeline is reduced for reasons other than those referred to in clause 3.6.8(f)(1);
(3)	the aggregate quantity of gas, if any, withdrawn by each Market Customer in excess of its authorised MDQ; and
(4)	the aggregate quantity of gas, if any, withdrawn by or on behalf of the Customers of a Retailer, where any such quantity of gas withdrawn by or on behalf of a Customer of that Retailer exceeds that Customer’s authorised MDQ.
(g)	Subject to clause 3.6.8(l) and the relevant service envelope agreement, the amount payable by the relevant Transmission Pipeline Owner in respect of that trading interval due to any failure by that Transmission Pipeline Owner to fulfil its obligations under its service envelope agreement is to be determined by VENCorp as follows:
UTPO	=	APC  x  QTPO 
		   DM  -  DS
where:
UTPO	is the amount of uplift payment payable by the relevant Transmission Pipeline Owner in $; 
APC	is the total amount in $ of ancillary payments attributable to transmission constraints in respect of that trading interval as determined by VENCorp in accordance with clause 3.6.8(a); 
QTPO  	is the quantity in GJ determined in accordance with clause 3.6.8(f)(1);
DM	is the quantity of gas, expressed in GJ, which VENCorp determines would have been injected at Longford in that trading interval in the absence of the transmission constraint; and
DS	is the quantity of gas, expressed in GJ, scheduled by VENCorp for injection at Longford in that trading interval.
(h)	Subject to clause 3.6.8(l), the amount of uplift payments payable by:
(1)	a Market Customer in respect of any gas it has withdrawn from the transmission system in that trading interval in excess of its authorised MDQ; and
(2)	a Retailer, in respect of the sum of all quantities of gas, if any, withdrawn from the transmission system by or on behalf of the Customers of that Retailer, where any such quantity of gas withdrawn by or behalf of a Customer exceeds that Customer’s authorised MDQ,
is to be determined as follows:
UUA 	=	APC  x  QUA	
		  DM  -  DS
where:
UUA	is the amount of uplift payments payable in $;
APC	is the total proportion of ancillary payments attributable to transmission constraints payable in respect of that trading interval as determined by VENCorp in accordance with clause 3.6.8(a);
QUA  	is:
(1)	the quantity, expressed in GJ, by which a Market Customer’s withdrawals of gas from the transmission system in that trading interval exceeded its authorised MDQ; plus
(2)	the aggregate of the quantities, expressed in GJ, by which each of a Retailer’s Customers exceeded their authorised MDQ;
DM	is the quantity of gas, expressed in GJ, which VENCorp determines would have been injected at Longford in that trading interval in the absence of the transmission constraint; and
DS	is the quantity of gas, expressed in GJ, scheduled by VENCorp for injection at Longford in that trading interval.
(i)	Subject to clause 3.6.8(l), if VENCorp reasonably believes that the capacity of the relevant pipeline was reduced for reasons other than those referred to in clause 3.6.8(f)(1), then the amount of uplift payment payable by:
(1)	a Market Customer in respect of any gas it has withdrawn from the transmission system; and
(2)	a Retailer, in respect of the sum of all quantities of gas, if any, withdrawn from the transmission system by or on behalf of its Customers,
is to be determined as follows:
USC 	=	(APC x QSC)    x   	QT
		  DM -  DS		QT
where:
USC	is the amount of uplift payments payable in $;
APC	is the total amount in $ of ancillary payments attributable to transmission constraints payable in respect of that trading interval as determined by VENCorp in accordance with clause 3.6.8(a); 
QSC	is the quantity in GJ by which the capacity of the relevant pipeline was reduced for reasons other than those referred to in clause 3.6.8(f)(1);
QT	is the total quantity of gas, expressed in GJ, withdrawn from the transmission system in that trading interval:
(1)	by that Market Customer; or
(2)	by or on behalf of that Retailer’s Customers,
as the case may be;
QT	is the total quantity of gas in GJ withdrawn by all Market Participants in that trading interval;
DM	is the quantity of gas, expressed in GJ, which VENCorp determines would have been injected at Longford in that trading interval in the absence of the transmission constraint; and
DS	is the quantity of gas, expressed in GJ, scheduled by VENCorp for injection at Longford in that trading interval.
(j)	Subject to clause 3.6.8(l), the amount of uplift payment payable by:
(1)	a Market Customer in respect of any gas it has withdrawn from the transmission system; and
(2)	a Retailer, in respect of the sum of all quantities of gas, if any, withdrawn from the transmission system by or on behalf of its Customers,
is to be determined as follows :
UC 	=	(APC  - UTPO  -  USC  -  UUA) x  (QT - QUA)	    
		                    (QT  -   QUA)		
where:
UC	is the amount of uplift payment payable in $;
APC	is the total amount in $ of ancillary payments attributable to transmission constraints payable in respect of that trading interval as determined by VENCorp in accordance with clause 3.6.8(a); 
UTPO	is the amount payable by the relevant Transmission Pipeline Owner in $ in respect of that trading interval, determined in accordance with clause 3.6.8(g);
QT	is the total quantity of gas, expressed in GJ, withdrawn from the transmission system by:
(1)	that Market Customer; or
(2)	by or on behalf of that Retailer’s Customers,
as the case may be;
QUA  	is the quantity, expressed in GJ:
(1)	by which that Market Customer’s withdrawals of gas from the transmission system in that trading interval exceeded its authorised MDQ; or
(2)	determined by aggregating all quantities of gas, if any, withdrawn from the transmission system by or on behalf of the Customers of that Retailer, where any such quantity of gas withdrawn by or behalf of a Customer exceeds that Customer’s authorised MDQ,
as the case may be;
QT	is the total quantity of gas in GJ withdrawn by all Market Participants in that trading interval;
QUA  	is the quantity, expressed in GJ, by which:
(1)	all Market Customers’ withdrawals of gas from the transmission system in that trading interval exceeded their authorised MDQs; plus
(2)	the sum of all quantities of gas withdrawn from the transmission system in that trading interval by or on behalf of the Customers of all Retailers, where any such quantity of gas withdrawn by or behalf of a Customer exceeded that Customer’s authorised MDQ; and
UUA	is the total amount of uplift payments, payable in $, by all Market Participants and Retailers in accordance with clause 3.6.8(h); and
USC	is the total amount, in $, of uplift payments payable by all Market Participants and Retailers in accordance with clause 3.6.8(i).
(k)	The amount of any uplift payments payable by each Market Participant in respect of ancillary payments in a trading interval other than those attributable to transmission constraints is to be determined by VENCorp as follows:
UA 	=	(TAP - APC) x QT
			QT
where:
UA	is the amount of uplift payments payable in $;
TAP	is the total amount of ancillary payments payable in respect of that  trading interval determined in accordance with clause 3.6.7;
APC	is the total amount in $ of ancillary payments attributable to transmission constraints payable in respect of that trading interval as determined by VENCorp in accordance with clause 3.6.8(a); 
QT	is the total quantity of gas, expressed in GJ, withdrawn from the transmission system by that Market Participant in that trading interval; and
QT	is the total quantity of gas in GJ withdrawn by all Market Participants in that trading interval.
(l)	The determination of uplift payments payable by Participants under this clause 3.6.8 is subject to the following:
(1)	if QUA      DM  -  DS
then:
the value of UUA is deemed to be equal to APC,
and:
(A)	UUA is equal to APC  x   QUA
				   QUA  ;
(B)	UTPO is 0;
(C)	USC is 0; and
(D)	UC is 0;
(2)	if QUA  <  DM  -  DS  but QUA    +  QSC    DM  -  DS
then the value of QSC is deemed to be equal to (DM  -  DS)  -  QUA  
and:
(A)	UTPO is deemed to be zero; and
(B)	UC is deemed to be zero; and
(3)	If QUA    +  QSC  <  DM  -  DS  but (QUA    +  QSC  +  QTPO)    (DM  -  DS)
then the value of QTPO is deemed to be equal to (DM  -  DS) - QUA   - QSC
and UC equals 0.
3.6.9	Determination of daily EoD linepack credits and daily EoD linepack debits
(a)	VENCorp must determine, in respect of each gas day, the daily EoD linepack credit or daily EoD linepack debit for each Market Participant, which shall be calculated as follows:
DCL = (PM x EDLD-1) - (PE x EDLD )
Where:
DCL	is, if DCL is a positive amount, the amount of the Market Participant’s daily EoD linepack credit or, if DCL is a negative amount, the amount of that Market Participant’s daily EoD linepack debit;
PM	is the market price for the gas day in respect of which the calculation is made;
EDLD-1	is the quantity of EoD linepack (if any) purchased by that Market Participant pursuant to an EoD linepack bid submitted in respect of the gas day immediately prior to the gas day in respect of which the calculation is made;
PE	is the price of EoD linepack for the gas day in respect of which the calculation is made as determined in accordance with clause 3.4.2; and
EDLD	is the quantity of EoD linepack (if any) purchased by that Market Participant pursuant to an EoD linepack bid submitted by it for the gas day in respect of which the calculation is made.
(b)	Each daily EoD linepack credit or daily EoD linepack debit calculated in respect of a Market Participant will be taken into account in determining that Market Participant’s settlement amount for the relevant billing period.
(c)	VENCorp must determine in respect of each gas day, the EoD linepack settlement surplus, if any, as follows:
SS = (PLC x LC)
Where:
SS	is the EoD linepack settlement surplus in $;
PLC	is the price, in $/GJ, of EoD linepack capacity (if any) for the gas day in respect of which the calculation is made as determined in accordance with clause 3.4.2; and
LC	is the amount of EoD linepack capacity, in GJ, as determined and published from time to time by VENCorp in accordance with clause 3.4.4.
(d)	Each billing period, VENCorp is to be credited with an amount equal to the sum of the EoD linepack settlement surpluses for each gas day in that billing period.
(e)	VENCorp must keep separate account of all amounts credited to VENCorp under clause 3.6.9(d).
(f)	The aggregate amount of all EoD linepack settlement surpluses credited to VENCorp in a financial year is to be used by VENCorp to offset its costs for the next financial year.
3.6.10	Linepack account
(a)	VENCorp must maintain a linepack account for the purpose of recording the linepack credit or  linepack debit which is required to be made in respect of each gas day (as determined in accordance with clause 3.6.10(c)).
(b)	VENCorp must record in the linepack account all linepack credits and linepack debits.
(c)	VENCorp must determine the amount of any linepack credit or linepack debit which it is required to record in the linepack account in respect of each gas day in accordance with the following formula:
Q   =    (I-W  -  EDL)  x  PM
Where:
Q	is the amount of the linepack debit (where Q is a positive amount) or the amount of the linepack credit (where Q is a negative amount) in respect of that gas day;
I	is the total quantity of gas injected into the transmission system during that gas day;
W	is the total quantity of gas withdrawn from the transmission system during that gas day; 
EDL	is the aggregate quantity of EoD linepack purchased by Market Participants in respect of that gas day in accordance with clause 3.4.2; and
PM	is the market price for that gas day.
(d)	The linepack account must record both quantities, expressed in joules, and monetary values.
3.6.11	Review of linepack account
VENCorp must establish, document and make available to Market Participants procedures for the regular review by the VENCorp Board of the linepack account and the basis upon which linepack transactions are to be funded.
3.6.12	Linepack payments
(a)	VENCorp must clear the balance on the linepack account each month by charging or making payments to Market Participants in accordance with this clause 3.6.12.
(b)	If the sum of daily linepack debits for the relevant month less the absolute sum of daily linepack credits for the relevant month (as determined under clause 3.6.10(c)) is a positive amount, each Market Participant who withdrew gas from the transmission system in that month must pay VENCorp an amount calculated as follows:
PM =	DB X 	QWi
		QWi
Where
PM	is the amount which the Market Participant must pay;
DB	is the sum of daily linepack debits for the relevant month less the absolute sum of daily linepack credits for the relevant month (as determined under clause 3.6.10(c));
QWi	is the quantity of gas withdrawn from the transmission system by that Market Participant in that month; and 
QWi	is the total quantity of gas withdrawn from the transmission system by all Market Participants in that month.
(c)	If the sum of daily linepack debits for the relevant month less the absolute sum of daily linepack credits for the relevant month (as determined under clause 3.6.10(c)) is a negative amount, VENCorp must pay each Market Participant who withdrew gas from the transmission system in that month an amount calculated as follows:
PV = CB X 	QWi
	QWi
Where:
PV	is the amount which VENCorp is required to pay to the Market Participant;
CB	is the sum of daily linepack debits for the relevant month less the absolute sum of daily linepack credits for the relevant month (as determined under clause 3.6.10(c));
QWi	is as defined in clause 3.6.12(b); and 
QWi	is as defined in clause 3.6.12(b).
(d)	Any amount which a Market Participant or VENCorp must pay pursuant to this clause 3.6.12 must be included by VENCorp in the Market Participant’s settlement statement for the relevant month.
3.6.13	Payment of settlement amount
(a)	Where the settlement amount for a Market Participant is a negative amount, the Market Participant must pay that amount to VENCorp in accordance with clause 3.6.16. 
(b)	Where the settlement amount for a Market Participant is a positive amount, VENCorp must pay that amount to the Market Participant in accordance with clause 3.6.17.
3.6.14	Preliminary statements
(a)	Within 7 business days after the end of each billing period, VENCorp must give each Market Participant a preliminary statement which sets out the market transactions of that Market Participant in that billing period and the settlement amount payable by or to that Market Participant.
(b)	The statements issued under this clause 3.6.14 must include supporting data for all amounts payable which must be sufficient to enable each Market Participant to audit the calculation of the amount payable by or to that Market Participant.
(c)	If the Market Participant reasonably believes there to be an error or discrepancy in the preliminary statement given to the Market Participant by VENCorp under clause 3.6.14(a), the Market Participant must notify VENCorp as soon as practicable of that error or discrepancy and VENCorp must review the preliminary statement.
(d)	If VENCorp considers that a preliminary statement contains an error or discrepancy after reviewing the preliminary statement under clause 3.6.14(c), VENCorp must notify all Market Participants whose final statements will be affected by the error or discrepancy within 7 days of the date on which the error or discrepancy first came to the attention of VENCorp and VENCorp must ensure that the error or discrepancy is corrected in the relevant final statements.
3.6.15	Final statements
(a)	No later than eighteen business days after the end of each billing period, VENCorp must give to each Market Participant a final statement stating the amounts payable by the Participant to VENCorp or payable by VENCorp to the Market Participant (subject to clause 3.6.22) in respect of the relevant billing period.
(b)	The statements issued under this clause 3.6.15 must include supporting data for all amounts payable which must be sufficient to enable each Market Participant to audit the calculation of the amount payable by or to that Market Participant.
3.6.16	Payment by Market Participants
No later than 2.00pm on the twentieth business day after the end of a billing period or 2.00pm on the second business day after receiving a final statement under clause 3.6.15, whichever is the later, each Market Participant must pay to VENCorp in cleared funds the settlement amount stated to be payable to VENCorp by that Market Participant in that Market Participant’s final statement, whether or not the Market Participant disputes, or continues to dispute, the amount payable.
3.6.17	Payment to Market Participants
By no later than 4.00pm on the day on which VENCorp is to be paid under clause 3.6.16, VENCorp must pay to each Market Participant in cleared funds the settlement amount stated to be payable to that Market Participant in that Market Participant’s final statement.
3.6.18	Disputes
(a)	If a dispute arises between a Market Participant and VENCorp concerning either:
(1)	the settlement amount stated in a preliminary statement provided under clause 3.6.14 to be payable by or to it; or 
(2)	the supporting data, 
they must each use reasonable endeavours to resolve the dispute within fifteen business days after the end of the relevant billing period.
(b)	Disputes in respect of final statements or the supporting data provided with them in accordance with clause 3.6.15 must be raised within twelve months of the relevant billing period.
(c)	Disputes raised under this clause 3.6.18 must be resolved by agreement or pursuant to the dispute resolution procedures set out in clause 7.2.
3.6.19	Settlement revisions 
(a)	If an amount in a final statement issued under clause 3.6.15: 
(1)	has been the subject of a dispute and the dispute has been resolved in any way which causes the amount payable to differ from the amount payable as set out in the final statement; or 
(2)	has been identified as being in error in accordance with clause 3.6.19(b) and the correct amount has been determined by VENCorp;
VENCorp must issue to each Market Participant affected by the resolution of the dispute or the correction of the error a revised statement for the relevant billing period setting out:
(3)	the amount payable by the Market Participant to VENCorp or the amount payable by VENCorp to the Market Participant (subject to clause 3.6.22); and
(4)	the adjustment to the final statement as agreed or determined plus interest calculated on a daily basis at the interest rate for the period from the payment date applicable to the final statement to which the adjustment relates to the payment date applicable to the revised statement issued under this clause 3.6.19(a).
(b)	If VENCorp becomes aware of an error in an amount stated in a final statement issued under clause 3.6.15 and in VENCorp’s reasonable opinion a Participant would be materially affected if a revision to the final statement was not made to correct the error, then VENCorp must issue revised statements for the relevant billing period in accordance with clause 3.6.19(a).
3.6.20	Payment of adjustments
(a)	VENCorp must specify the time and date on which a payment of an adjustment under a revised statement issued under clause 3.6.19 is due, which date must be not less than ten business days and not more than fifteen business days after the issue of that revised statement. 
(b)	By no later than the time and date specified by VENCorp pursuant to clause 3.6.20(a), each Market Participant must pay to VENCorp in cleared funds the net amount stated to be payable by that Market Participant in the revised statement issued to it under clause 3.6.19.
(c)	Subject to clause 3.6.22, on the day on which VENCorp is to be paid under clause 3.6.20(b), VENCorp must pay to each Market Participant in cleared funds the net amount stated to be payable to that Market Participant in the revised statement issued to it under clause 3.6.19.
3.6.21	Payment default procedure
(a)	Each of the following events is a default event in relation to a Market Participant:
(1)	the Market Participant does not pay any money due for payment by it under these Rules by the appointed time on the due date;
(2)	VENCorp does not receive payment in full of any amount claimed by VENCorp under any credit support in respect of a Market Participant, within ninety minutes after the due time for payment of that claim;
(3)	the Market Participant fails to provide credit support required to be supplied under these Rules by the appointed time on the due date;
(4)	it is or becomes unlawful for the Market Participant to comply with any of its obligations under these Rules or any other obligation owed to VENCorp or it is claimed to be so by the Market Participant;
(5)	it is or becomes unlawful for any Credit Support Provider in relation to the Market Participant to comply with any of its obligations under these Rules or any other obligation owed to VENCorp or it is claimed to be so by that Credit Support Provider;
(6)	an authorisation from a government body necessary to enable the Market Participant or a Credit Support Provider which has provided credit support for that Market Participant to carry on their respective principal businesses or activities ceases to have full force and effect;
(7)	the Market Participant or a Credit Support Provider which has provided credit support for that Market Participant ceases or is likely to cease to carry on its business or a substantial part of its business;
(8)	the Market Participant or a Credit Support Provider which has provided credit support for that Market Participant enters into or takes any action to enter into an arrangement (including a scheme of arrangement), composition or compromise with, or assignment for the benefit of, all or any class of their respective creditors or members, or a moratorium involving any of them;
(9)	the Market Participant or a Credit Support Provider which has provided credit support for that Market Participant states that it is unable to pay from its own money its debts as and when they fall due for payment;
(10)	a receiver or receiver and manager is appointed in respect of any property of the Market Participant or a Credit Support Provider which has provided credit support for that Market Participant;
(11)	an administrator, provisional liquidator, liquidator, trustee in bankruptcy or person having a similar or analogous function is appointed in respect of the Market Participant or a Credit Support Provider which has provided credit support for that Market Participant, or any action is taken to appoint any such person;
(12)	an application or order is made for the winding up or dissolution or a resolution is passed or any steps are taken to pass a resolution for the winding up or dissolution of the Market Participant or a Credit Support Provider which has provided credit support for that Market Participant;
(13)	a notice under section 572 of the Corporations Law is given to the Market Participant or a Credit Support Provider which has provided credit support for that Market Participant unless such application or order is rejected as being frivolous;
(14)	the Market Participant or a Credit Support Provider which has provided credit support for that Market Participant dies or is dissolved unless such notice of dissolution is discharged; and
(15)	the Market Participant or a Credit Support Provider which has provided credit support for that Market Participant is taken to be insolvent or unable to pay its debts under any applicable legislation.
(b)	Where a default event has occurred in relation to a Market Participant, VENCorp may:
(1)	issue a default notice which specifies:
(A)	the nature of the alleged default; and 
(B)	if VENCorp considers that the default is capable of remedy, that the Market Participant must remedy the default within 24 hours of the issue of the default notice; and/or
(2)	immediately issue a suspension notice in accordance with clause 3.7.7 if VENCorp considers that the default is not capable of remedy and that failure to issue a suspension notice would be likely to expose other Market Participants to greater risk; and/or
(3)	if it has not already done so, make a claim upon any credit support held in respect of the Market Participant for such amount as VENCorp determines represents the amount of any money actually or contingently owing by the Market Participant to VENCorp pursuant to these Rules.
(c)	If:
(1)	VENCorp considers that a default event is not capable of remedy in accordance with clause 3.6.21(b)(2); or
(2)	a default event is not remedied within 24 hours of the issue of the default notice or any later deadline agreed to in writing by VENCorp; or 
(3)	VENCorp receives notice from the defaulting Market Participant that it is not likely to remedy the default specified in the default notice, 
then VENCorp may issue a suspension notice in accordance with clause 3.7.7 under which VENCorp notifies the defaulting Market Participant that it is prohibited from doing all or any of the following things:
(4)	submitting nominations, inc/dec offers and/or EoD linepack bids;
(5)	injecting gas, or tendering gas for injection, into the transmission system; or
(6)	withdrawing gas, or tendering gas for withdrawal, from the transmission system.
3.6.22	Maximum total payment in respect of a billing period
(a)	For the purposes of this clause 3.6.22, the maximum total payment in respect of a billing period is equal to:
(1)	the aggregate of the amounts received by VENCorp from Market Participants under clause 3.6.16 in respect of that billing period by 4.00 pm on the payment date; plus
(2)	if one or more Market Participants are in default, the aggregate amount which VENCorp is able to obtain from the credit support provided by such Market Participants under clause 3.7 before 4.00 pm on the payment date; less
(3)	the aggregate amount of all market fees and other payments received by VENCorp pursuant to clause 3.6.5(b)(4).
(b)	For the purpose of clause 3.6.22(a), any payment received by VENCorp from a Market Participant in respect of a billing period shall be deemed to be made, and may be applied by VENCorp, in satisfaction of the market fees and other payments specified in clause 3.6.5(b)(4) payable to VENCorp by that Market Participant (as specified in the final statement issued to that Market Participant in respect of that billing period) before it is applied by VENCorp in satisfaction of any other obligation or liability.
(c)	If the maximum total payment in respect of a billing period is not sufficient to meet the aggregate of the net amounts payable by VENCorp to each of the Market Participants to whom payments are to be made in respect of the billing period, then the amount payable by VENCorp to each relevant Market Participant in respect of that billing period is to be reduced by applying the following formula:
AAP  =  SAP  x  
where:
AAP	is the reduced amount payable by VENCorp to the relevant Market Participant in respect of the relevant billing period;
SAP	is the net amount that would have been payable to the relevant Market Participant for the relevant billing period but for the application of this clause 3.6.22.
A 	is the maximum total payment in respect of the billing period; and
B 	is the aggregate of the net amounts payable by VENCorp to Market Participants under clause 3.6.17 in respect of the billing period.
3.6.23	Interest on overdue amounts
(a)	A Market Participant or VENCorp, as the case may be, must pay interest on any unpaid moneys due and payable by it under this clause 3.6.23.
(b)	The rate of interest payable under clause 3.6.23(a) is the default interest rate calculated as simple interest on a daily basis from the date payment was due, up to and including the date on which payment is made, with interest compounding on monthly rests on the last day of each month whilst the unpaid moneys remain outstanding.

3.7	PRUDENTIAL REQUIREMENTS

3.7.1	Purpose
The purpose of the prudential requirements is to ensure the effective operation of the market by providing a level of comfort that Market Participants will meet their obligations to make payments as required under these Rules.
3.7.2	Provision of security
(a)	Subject to clause 3.7.2(c), a Market Participant must provide and maintain a security complying with the requirements of this clause 3.7.
(b)	If VENCorp believes it is likely that the amount payable by VENCorp to that Market Participant under these Rules in respect of a period will consistently exceed the amount payable to VENCorp by that Market Participant under these Rules in respect of that period, then VENCorp may exempt the Market Participant from the requirement to provide a security under clause 3.7.2(a) for that period.
(c)	If, under clause 3.7.2(b), VENCorp has exempted a Market Participant from the requirement to provide a security under clause 3.7.2(a), then VENCorp may vary or cancel the exemption at any time by giving written notice of the variation or cancellation of the exemption to the Market Participant.
3.7.3	Form of security
The security provided by a Market Participant under this clause 3.7 must be either:
(a)	a bank guarantee in a form and from a bank acceptable to VENCorp; or
(b)	another immediate, irrevocable and unconditional commitment in a form and from a bank or other institution acceptable to VENCorp.
3.7.4	Amount of security
(a)	Subject to clause 3.7.2(b), prior to the end of each financial year VENCorp must determine and provide written confirmation to each Market Participant of that Market Participant’s minimum exposure, calculated as VENCorp’s reasonable estimate of the market fees payable by the Market Participant to VENCorp in respect of a billing period in the following financial year.
(b)	VENCorp may review its determination of a Market Participant’s minimum exposure at any time, provided that any change to a Market Participant’s minimum exposure will apply no earlier than thirty days following notification by VENCorp to that Market Participant of that change or such earlier period agreed by the Board of Directors of VENCorp. 
(c)	Each Market Participant must procure that at all times the aggregate undrawn and unclaimed amounts of current and valid security held by VENCorp in respect of that Market Participant is not less than that Market Participant’s minimum exposure.
(d)	To diminish the possibility of incurring a margin call under clause 3.7.10, a Market Participant may in its absolute discretion provide to VENCorp a security or securities in accordance with clause 3.7.3 for an aggregate amount which exceeds its minimum exposure.
3.7.5	Replacement security
(a)	If:
(1)	an existing security provided by a Market Participant under this clause 3.7 is due to expire or terminate; and
(2)	after that security expires or terminates, the maximum amount which VENCorp will be entitled to be paid in aggregate under any remaining security or securities provided by the Market Participant under this clause 3.7 will be less than Market Participant’s minimum exposure,
then the Market Participant must deliver to VENCorp, at least ten business days prior to the time at which that existing security is due to expire or terminate, a replacement security which:
(3)	is of sufficient value to enable the Market Participant to comply with clause 3.7.4(c);
(4)	complies with the requirements of this clause 3.7; and
(5)	will take effect no later than the date on which the existing security is due to expire or terminate.
(b)	If:
(1)	a Market Participant fails to comply with clause 3.7.5(a); and
(2)	that Market Participant does not remedy that failure within 24 hours after being notified by VENCorp of the failure,
then VENCorp must give the Market Participant a suspension notice in accordance with clause 3.7.7.
3.7.6	Drawdown of security
(a)	If VENCorp exercises its rights in accordance with clause 3.6.21 under a security provided by a Market Participant under this clause 3.7, then VENCorp must notify the Market Participant.
(b)	If, as a result of VENCorp exercising its rights under a security provided by a Market Participant under this clause 3.7, the maximum amount which VENCorp is entitled to be paid under the security or securities provided by the Market Participant under this clause 3.7 is less than the Market Participant’s minimum exposure, then, within 24 hours of receiving a notice under clause 3.7.6(a), the Market Participant must provide an additional security to ensure that at all times, it complies with the requirements of this clause 3.7. 
(c)	If a Market Participant fails to comply with clause 3.7.6(b) within the time period referred to in that clause, then VENCorp must give the Market Participant a suspension notice in accordance with clause 3.7.7.
3.7.7	Suspension of a Market Participant
(a)	As soon as practicable after a suspension notice is issued by VENCorp under these Rules, VENCorp must: 
(1)	publish the suspension notice; and
(2)	place a notice in a newspaper generally circulating in Victoria stating that the Market Participant has been suspended.
(b)	VENCorp must revoke a suspension notice if:
(1)	in the case of a default event, the default event is remedied; or
(2)	in the case of a failure to maintain compliance with prudential requirements under this clause 3.7, that failure has been remedied; and 
(3)	there are no other circumstances in existence which would entitle VENCorp to issue a suspension notice,
except that VENCorp must not revoke a suspension notice more than one month after it was issued.
(c)	If a suspension notice is revoked, VENCorp must publicise that fact in the same manner in which the suspension notice was publicised in accordance with clause 3.7.7(a).
(d)	From the time that VENCorp issues a suspension notice to a Market Participant under these Rules, the Market Participant is ineligible to submit nominations, inc/dec offers or EoD linepack bids to the extent specified in the notice, until such time as VENCorp notifies the Market Participant and all other relevant Market Participants that the suspension has been revoked.
(e)	A Market Participant must comply with a suspension notice issued to it under these Rules.
(f)	Following the issue of a suspension notice to a Market Participant, VENCorp may do all or any of the following to give effect to the suspension notice:
(1)	reject any nomination, inc/dec offer or EoD linepack bid submitted by that Market Participant; 
(2)	refuse to accept delivery of any gas injected, or tendered for injection, by that Market Participant; 
(3)	take such action as VENCorp considers necessary to prevent that Market Participant from injecting or withdrawing gas, including without limitation taking any action necessary to curtail the supply of gas to that Market Participant; and
(4)	withhold the payment of any amounts otherwise due to that Market Participant under these Rules.
(g)	If VENCorp does any of the things referred to in clause 3.7.7(f) it must promptly publish a notice of that fact.
(h)	If:
(1)	VENCorp has issued a suspension notice to a Market Participant due to a default event and in VENCorp’s reasonable opinion the Market Participant is incapable of rectifying the default event for any reason; or
(2)	VENCorp has issued a suspension notice to a Market Participant due to a failure by the Market Participant to continue to satisfy the prudential requirements and in VENCorp’s reasonable opinion the Market Participant is incapable of rectifying that failure for any reason,
VENCorp must deregister that Market Participant as soon as practicable and promptly publish a notice of that fact.
3.7.8	Trading limits
(a)	Subject to clause 3.7.8(b), VENCorp must set a trading limit for each Market Participant.
(b)	If, under clause 3.7.2(c), VENCorp has exempted a Market Participant from the requirement to provide a security under clause 3.7.2(b) for a period, then VENCorp must not set a trading limit for that Market Participant for the period during which that exemption applies.
(c)	The trading limit for a Market Participant at any time must not be less than the greater of:
(1)	the Market Participant’s minimum exposure; and
(2)	85% of the total value of the security provided by the Market Participant to VENCorp under clauses 3.7.3(a) and (b).
3.7.9	Monitoring
(a)	Each day, VENCorp must review its actual exposure to each Market Participant in respect of previous billing periods under these Rules.
(b)	In calculating VENCorp’s actual exposure to a Market Participant under clause 3.7.9(a), the period between the start of the billing period in which the review occurs and the start of the gas day immediately following the day on which the review occurs is to be treated as a previous billing period.
(c)	In calculating VENCorp’s actual exposure to a Market Participant under clause 3.7.9(a), VENCorp must take into account:
(1)	outstanding settlement amounts for the Market Participant in respect of previous billing periods; and 
(2)	settlement amounts for the Market Participant for trading intervals from the start of the billing period in which the review occurs to the end of the gas day on which the review occurs based on:
(A)	actual market prices or, if actual market prices are not available for all or part of a gas day, the market prices forecast for the relevant gas day as published in the relevant final operating schedule determined by VENCorp in accordance with clause 3.1.12; and
(B)	actual metered quantities for the Market Participant or, if actual metered quantities are not available for a trading interval, then a trading imbalance for that trading interval determined by VENCorp as the average of the trading imbalances of that Market Participant for the corresponding trading interval on the corresponding gas days of the four previous weeks.
(d)	If VENCorp calculates that its actual exposure to a Market Participant exceeds the greater of 
(1)	the Market Participant’s minimum exposure; and 
(2)	80% of the Market Participant’s trading limit, 
then VENCorp must inform the Market Participant accordingly.
3.7.10	Margin calls
(a)	If VENCorp calculates that its exposure to a Market Participant exceeds the Market Participant’s trading limit, then VENCorp must make a margin call on that Market Participant by notice to the Market Participant.
(b)	If VENCorp makes a margin call on a Market Participant under clause 3.7.10(a), then the Market Participant must satisfy the margin call within the period determined in accordance with clause 3.7.10(c) by either:
(1)	providing to VENCorp an additional security or securities complying with the requirements of this clause 3.7 which enables VENCorp to increase the Market Participant’s trading limit to a level which exceeds VENCorp’s actual exposure to the Market Participant; or
(2)	prepaying a portion of the amount payable or which will become payable in respect of previous billing periods sufficient to reduce VENCorp’s actual exposure to the Market Participant to below the Market Participant’s trading limit.
(c)	The period within which a margin call must be satisfied under clause 3.7.10(b) is:
(1)	if the margin call is made on a business day before 10:00 am, then the period commences at the time the margin call is made and finishes at 2:00 pm on that business day; and
(2)	if clause 3.7.10(c)(1) does not apply, then the period commences when the margin call is made and ends at 10:00 am on the first business day to occur after the margin call is made.
(d)	For the purposes of these Rules, a prepayment under clause 3.7.10(b)(2) is taken to relate to the earliest billing period in respect of which the relevant Market Participant owes VENCorp an amount of money under these Rules and, if the amount the Market Participant owes under these Rules in respect of that billing period is less than the amount of the prepayment, then the excess is taken to relate to the billing periods occurring immediately after the earliest billing period in respect of which the relevant Market Participant owes VENCorp an amount of money under these Rules in chronological order until there is no excess.
(e)	If a Market Participant fails to satisfy a margin call by providing an additional security or making a prepayment under clause 3.7.10(b) within the time referred to in that clause, then VENCorp must give the Market Participant a suspension notice.
3.7.11	Confidentiality
All information provided by a Market Participant in relation to its financial circumstances must be treated by VENCorp as confidential information in accordance with clause 5.4.

CHAPTER 4.	TECHNICAL MATTERS

4.1	Connection to the Transmission System

4.1.1	Statement of purpose
This clause 4.1:
(a)	provides the framework for connection to the transmission system; and
(b)	has the following aims:
(1)	to detail the principles and guidelines governing connection to the transmission system;
(2)	to establish the process to be followed by a Transmission Pipeline Owner and a Connection Applicant to establish or modify a connection to the transmission system; and
(3)	to establish the system operation and security requirements for connection to the transmission system.
4.1.2	Principles
This clause 4.1 is based on the following principles relating to connection to the transmission system:
(a)	All persons shall have the opportunity to form a connection to the transmission system and have access to the services provided by the transmission system.
(b)	The terms and conditions on which connection to the transmission system and provision of connection services are to be set out in a commercial agreement to be entered into between the relevant Transmission Pipeline Owner and the Connection Applicant.
(c)	If requested by a Connected Party or by the relevant Transmission Pipeline Owner, the relevant Transmission Pipeline Owner and the Connected Party must document the terms of any connection arrangements made prior to the commencement date and the resulting document will then be deemed to be a connection agreement for the purposes of these Rules.
(d)	This clause 4.1 applies to:
(1)	all connection agreements made after the commencement date;
(2)	all deemed connection agreements created pursuant to clause 4.1.2(c); and
(3)	all requests to establish connection or modify an existing connection after the commencement date.
(e)	This clause 4.1 is not intended to, nor is it to be read or construed as having the effect of:
(1)	altering any of the terms of a connection agreement made prior to the commencement date; or
(2)	altering the contractual rights or obligations of any of the parties under a connection agreement as between the relevant Transmission Pipeline Owner and the Connected Party made prior to the commencement date; or
(3)	relieving the parties to a connection agreement made prior to the commencement date of their contractual obligations under that agreement.
(f)	Subject to clause 4.1.2(e), if any right or obligation of a Connected Party under a connection agreement is inconsistent with any provision of these Rules, the provisions of these Rules shall prevail.
4.1.3	Obligations of the Transmission Pipeline Owner
A Transmission Pipeline Owner must:
(a)	receive and process applications for connection or modification of a connection which are submitted to it and must enter into a connection agreement with each Connected Party and any other person to which it has provided a connection in accordance with this clause 4.1;
(b)	ensure that every connection agreement to which it is a party complies with, and is not inconsistent with, this clause 4.1;
(c)	consult with VENCorp regarding the system operation and security requirements of proposed connections to its pipeline; and
(d)	use its reasonable endeavours to comply with all reasonable requests of the Connection Applicant relating to its connection requirements.
4.1.4	Obligations of VENCorp
VENCorp must:
(a)	review all proposed connections from a system operation and security perspective;
(b)	establish system operation and security standards and requirements for connections; and
(c)	use its reasonable endeavours to comply with all reasonable requirements of the Connection Applicant and the relevant Transmission Pipeline Owner relating to the commissioning of connection equipment.
4.1.5	Obligations of Connected Parties
(a)	Each Connected Party must ensure that all connection equipment which is owned, operated or controlled by it at all times comply with applicable requirements and conditions for connection in accordance with its connection agreement with the Transmission Pipeline Owner.
(b)	A Connection Applicant must:
(1)	comply with the reasonable requirements of the Transmission Pipeline Owner in respect of the design requirements of connection equipment proposed to be connected to the transmission system;
(2)	not make any material modification or addition to any connection equipment which is the subject of a connection agreement without the prior written consent of the relevant Transmission Pipeline Owner and VENCorp;
(3)	provide load forecast information to the relevant Transmission Pipeline Owner and VENCorp in accordance with clause 4.1.6(c); and
(4)	allow the Transmission Pipeline Owner to participate in the commissioning of connection equipment which is to be connected to the transmission system.
4.1.6	Application for connection
(a)	A person who wishes to connect to the transmission system may make an application to connect in accordance with this clause 4.1.6.
(b)	An application to connect made by a person who wishes to connect to the transmission system must contain the information specified in clause 4.1.6(c) and must be submitted, together with the relevant application fee, to the relevant Transmission Pipeline Owner.
(c)	The connection application must include:
(1)	details of the location of the connection point and proposed specifications of the connection equipment;
(2)	the date by which the connection is desired;
(3)	details of the forecast load requirements of the connection point, including maximum daily quantity, maximum hourly quantity and maximum and minimum operating pressures; and
(4)	such other information as the relevant Transmission Pipeline Owner may reasonably request to enable it to assess the application to connect and prepare an offer to connect.
(d)	Within six months of the commencement date, VENCorp must determine the relevant application fee (if any) payable under clause 4.1.6(b) by a person making an application to connect to the transmission system.
4.1.7	VENCorp to approve application in principle
(a)	The relevant Transmission Pipeline Owner must submit details of the load requirements of the proposed connection point (including the information referred to in clause 4.1.6(c)) to VENCorp for approval and for allocation of any available authorised MDQ to the Connection Applicant in accordance with clause 5.3 as soon as reasonably practicable and in any event within twenty business days of receipt of an application to connect (or within such longer period as the relevant Transmission Pipeline Owner and the Connection Applicant may agree).
(b)	Within twenty business days of receipt of a proposal for a connection, VENCorp must approve or reject the proposed connection in accordance with principles and procedures to be developed by VENCorp and give notice of the approval or rejection to the relevant Transmission Pipeline Owner.
(c)	VENCorp may reject a proposed connection if:
(1)	in VENCorp’s reasonable opinion, the proposed connection has potential to adversely and materially affect the operation or the security of the transmission system; or
(2)	it does not comply with, or is inconsistent with, any provision of these Rules.
(d)	If VENCorp rejects a proposed connection, VENCorp must notify the relevant Transmission Pipeline Owner of its reasons for doing so.
(e)	The relevant Transmission Pipeline Owner and the Connection Applicant must provide VENCorp with any information which VENCorp may reasonably request to enable it to assess the proposed connection.
(f)	Within six months of the commencement date, VENCorp must develop the principles and procedures for approving or rejecting a proposed connection referred to in clause 4.1.7(b) and VENCorp must procure that those principles and procedures be incorporated into these Rules in accordance with the rules change procedure in chapter 8.
4.1.8	Offer to connect
(a)	Within twenty business days after the proposed connection has been approved in principle by VENCorp (or such longer period as the relevant Transmission Pipeline Owner and the Connection Applicant may agree), the relevant Transmission Pipeline Owner must prepare and make an offer to connect the Connection Applicant’s pipeline to the transmission system.
(b)	The offer to connect must contain the proposed terms and conditions for connection to the transmission system.
(c)	The offer to connect must be fair and reasonable and must be consistent with the safe and reliable operation of the transmission system in accordance with these Rules.
(d)	The relevant Transmission Pipeline Owner must use its reasonable endeavours to provide the Connection Applicant with an offer to connect in accordance with the reasonable requirements of the Connection Applicant, including without limitation, the location and load requirements of the proposed connection point.
(e)	Both the relevant Transmission Pipeline Owner and the Connection Applicant are entitled to negotiate with each other in respect of the provision of connection and any other matters relevant to the provision of connection. If negotiations occur, the relevant Transmission Pipeline Owner and the Connection Applicant must conduct such negotiations in good faith.
(f)	The offer to connect must define the basis for determining transmission connection charges in accordance with the relevant Transmission Pipeline Owner’s access arrangement, if any.
4.1.9	Finalisation of connection agreements
(a)	If the Connection Applicant accepts an offer to connect, the Connection Applicant must:
(1)	agree to be bound by all relevant provisions of these Rules; and
(2)	subject to clause 4.1.10, enter into a connection agreement with the relevant Transmission Pipeline Owner.
(b)	The provision of connection by the relevant Transmission Pipeline Owner may be made subject to gaining environmental, planning or other regulatory or statutory approvals for any pipeline equipment or connection equipment.
(c)	Each connection agreement must be based on the offer to connect as varied by agreement between the parties.
4.1.10	Approval of connection agreements by VENCorp
(a)	A Transmission Pipeline Owner and a Connection Applicant must not enter into a connection agreement unless it has been approved by VENCorp.
(b)	A Transmission Pipeline Owner must submit each connection agreement which it proposes to enter into with a Connection Applicant, in the form agreed by the relevant Transmission Pipeline Owner and the Connection Applicant, to VENCorp within two business days after the terms of the proposed connection agreement have been agreed by the relevant Transmission Pipeline Owner and the Connection Applicant.
(c)	The relevant Transmission Pipeline Owner must, at the same time as it submits a connection agreement for approval by VENCorp, either:
(1)	confirm that there has been no material change to the information provided to VENCorp pursuant to clause 4.1.7 in relation to the proposed connection; or
(2)	provide VENCorp with full details of the load requirements of the proposed connection point to the extent that such requirements differ from the requirements submitted to VENCorp pursuant to clause 4.1.7 and any other change to the information provided to VENCorp pursuant to that clause.
(d)	Within ten business days of receipt by VENCorp of a proposed connection agreement pursuant to clause 4.1.10(b), VENCorp must approve the proposed connection agreement or reject the proposed connection agreement.
(e)	VENCorp may reject a proposed connection agreement if:
(1)	in VENCorp’s reasonable opinion, the proposed connection which is the subject of that connection agreement has potential to adversely and materially affect the operation or security of the transmission system; or
(2)	it does not comply with, or is inconsistent with, any provision of these Rules.
(f)	The relevant Transmission Pipeline Owner and the Connection Applicant must provide VENCorp with any information which VENCorp may reasonably request to enable it to assess the proposed connection agreement.
4.1.11	Consultation
The relevant Transmission Pipeline Owner must consult with VENCorp in relation to a proposed connection prior to submission of the proposed connection agreement relating to that connection for approval by VENCorp with the intent of facilitating the approval by VENCorp of that connection agreement.
4.1.12	Confidential information
(a)	All data and information provided by a Transmission Pipeline Owner or a Connection Applicant under this clause 4.1 must be:
(1)	prepared, given and used in good faith;
(2)	treated as confidential information; and
(3)	protected from being disclosed or made available by the recipient to a third party, except for the purpose of enabling the relevant Transmission Pipeline Owner and VENCorp to assess the application for connection.
(b)	If a Connection Applicant or relevant Transmission Pipeline Owner becomes aware of any material change to any information contained in or relevant to an application to connect then it must promptly notify the other party in writing of that change.
4.1.13	System balancing arrangements
(a)	VENCorp may require, as a condition of connection of a transmission pipeline to the transmission system, that the Interconnecting Pipeline Owner which operates the transmission pipeline which is proposed to be connected must enter into an agreement with VENCorp relating to the operation of their respective transmission pipeline systems and an Interconnecting Pipeline Owner must comply with any such requirement.
(b)	An agreement referred to in clause 4.1.13(a), may make arrangements relating to, amongst other things:
(1)	the balancing, monitoring and regulation of gas flows between the transmission system and the pipeline which is proposed to be connected;
(2)	the scheduling of gas flows in accordance with the nominations and inc/dec offers of Market Participants who wish to transport gas across the transfer point at which the Interconnected Pipeline Owner’s pipeline is connected to the transmission system;
(3)	the maintenance of a balancing account;
(4)	the deployment of system capacity and system optimisation;
(5)	operating pressures; and
(6)	the maintenance of the security of the transmission system and the transmission pipeline which is proposed to be connected.
4.1.14	Interpretation
For the purpose of this clause 4.1, in relation to a connection, a reference to a “relevant Transmission Pipeline Owner” is to be construed as a reference to the Transmission Pipeline Owner which owns or controls the pipeline to which that connection relates or which is the subject of that connection.

4.2	LNG STORAGE

4.2.1	Purpose of this clause
This clause 4.2 sets out:
(a)	the obligations of the LNG Storage Provider relating to the operation of the LNG storage facility and the provision of LNG storage capacity;
(b)	the responsibilities of VENCorp relating to the LNG reserve;
(c)	the rights and obligations of Market Participants who hold LNG storage capacity;
(d)	requirements relating to the transfer of LNG storage capacity and LNG stock; and
(e)	the rights and obligations of VENCorp, the LNG Storage Provider and Market Participants relating to the maintenance of sufficient LNG stock to ensure the security of the transmission system and to satisfy VENCorp’s operational requirements.
4.2.2	Obligations of VENCorp
(a)	For a period of two years from the commencement date, VENCorp is responsible for scheduling LNG injection offers and managing the LNG reserve.
(b)	Prior to the expiry of the period referred to in clause 4.2.2(a), VENCorp must establish a committee to review VENCorp’s role in relation to the LNG reserve in accordance with the public consultation procedures and that committee must determine either:
(1)	that VENCorp should cease to be entitled to any LNG storage capacity constituting the LNG reserve; or
(2)	that VENCorp’s role in relation to the LNG reserve and its entitlement to LNG storage capacity constituting the LNG reserve should continue for a period not exceeding twelve months or such other period that the committee reasonably considers to be appropriate.
(c)	If the committee established under clause 4.2.2(b) determines that VENCorp’s role in relation to the LNG reserve and its entitlement to LNG storage capacity should either:
(1)	cease at the expiration of two years from the commencement date, then VENCorp will cease to be responsible for the LNG reserve and will cease to be entitled to any LNG storage capacity constituting the LNG reserve, then all provisions of these Rules relating to the LNG reserve will cease to have effect on and from the date immediately following the expiry of two years from the commencement date; or
(2)	continue for a period of not more than twelve months or such other period that the committee reasonably considers to be appropriate, then if the Regulator approves, VENCorp will continue to be responsible for the LNG reserve and will continue to be entitled to LNG storage capacity constituting the LNG reserve, and all provisions of these Rules relating to the LNG reserve will continue to have effect for the duration of that period.
(d)	The provisions of this clause 4.2 are subject always to clause 4.2.2(c).
4.2.3	Obligations of the LNG Storage Provider
(a)	The LNG Storage Provider must ensure that, subject to the terms and conditions of these Rules and the right of Market Participants who hold LNG storage capacity to make LNG injection offers, the LNG storage facility is utilised with the objective of maintaining LNG stock at the highest level possible.
(b)	The LNG Storage Provider must operate the LNG storage facility in accordance with the  scheduling instructions issued by VENCorp in accordance with these Rules.
(c)	The LNG Storage Provider must maintain a register of the holders of LNG storage capacity and register transfers of LNG storage capacity and LNG stock in accordance with clauses 4.2.5 and 4.2.6.
4.2.4	BOC Agreement
(a)	The LNG Storage Provider must, subject to the terms and conditions of the BOC Agreement, keep VENCorp informed in a timely manner of all matters or circumstances relating to the BOC Agreement or the operation of the LNG storage facility which may affect the ability of VENCorp to schedule LNG injection offers or use the LNG reserve.
(b)	The LNG Storage Provider must notify VENCorp on or before the twelfth day of each month of the following information relating to the operation of the BOC Agreement:
(1)	the minimum and maximum quantity of gas which the LNG Storage Provider may order for liquefaction by BOC in the following month under the BOC Agreement; and
(2)	if known, BOC’s requirements for gas and LNG stock in the following month.
(c)	If any provision of these Rules with which the LNG Storage Provider is bound to comply is inconsistent with any term of the BOC Agreement, then the term of the BOC Agreement will prevail.
(d)	The LNG Storage Provider must not terminate or vary the BOC Agreement without the consent of VENCorp (whose consent must not be unreasonably withheld or delayed).
4.2.5	LNG storage capacity
(a)	VENCorp must not do anything, or omit to do anything, which would adversely affect BOC’s LNG storage entitlement under the BOC Agreement.
(b)	Unless and until VENCorp otherwise agrees, the LNG Storage Provider must make available 3,000 tonnes of LNG storage capacity for the operation of the LNG reserve in accordance with clause 4.2.9. 
(c)	If VENCorp requests, any LNG storage capacity which is not required to be made available to BOC or is not allocated to Market Participants must be made available to VENCorp and will comprise part of the LNG reserve.
(d)	A Market Participant must hold LNG storage capacity in order to use the LNG storage facility. 
(e)	The LNG Storage Provider must maintain and keep updated a register of holders of LNG storage capacity, which must include the following information:
(1)	the identity of each holder of LNG storage capacity;
(2)	the amount of storage space to which each holder of LNG storage capacity is entitled; and
(3)	the quantity of LNG stock held on behalf of each holder of LNG storage capacity.
(f)	The register of holders of LNG storage capacity may be maintained and stored in a computer or other electronic device or database.
4.2.6	Transfers of LNG storage capacity and LNG stock
(a)	A Market Participant may at any time:
(1)	transfer all or part of its LNG storage capacity; or
(2)	transfer all or part of its LNG stock,
to another Market Participant, subject to and in accordance with this clause 4.2.6.
(b)	A Market Participant may not transfer LNG storage capacity or LNG stock if as a result the transferor or the transferee would have LNG stock in excess of the LNG storage capacity to which it is entitled.
(c)	A transfer of LNG storage capacity and/or LNG stock may only be expressed to take effect on the start of a gas day and any such transfer which purports to take effect at any other time shall be invalid.
(d)	The LNG Storage Provider must not reject a transfer in respect of which the requirements of this clause 4.2.6 are satisfied.
(e)	Where a Market Participant proposes to make an LNG storage transfer, both the transferor and transferee must give notice of the proposed LNG storage transfer to the LNG Storage Provider, specifying:
(1)	the identity of the transferor and the transferee;
(2)	the amount of the LNG storage capacity and/or LNG stock the subject of the transfer; and
(3)	the gas day on the commencement of which the LNG storage transfer is to be effective.
(f)	A proposed LNG storage transfer must be notified to the LNG Storage Provider by the transferor and the transferee by no later than 7.00 am on the day on which the gas day specified in the notice referred to in clause 4.2.6(e)(3) starts.
(g)	The LNG Storage Provider must: 
(1)	register an LNG storage transfer which complies with this clause 4.2.6 as soon as reasonably practicable after it has been received; and
(2)	notify VENCorp of an LNG storage transfer and the amount of the LNG storage capacity and/or LNG stock transferred by no later than 8.00 am on the day on which the gas day starts on the commencement of which that LNG storage transfer is to be effective.
(h)	The amount of LNG storage capacity and LNG stock which a Market Participant holds will be determined by the register of LNG storage capacity maintained by the LNG Storage Provider in accordance with clause 4.2.5(e). The LNG Storage Provider will not be required to have regard to any LNG storage capacity or LNG stock which a Market Participant purports to hold other than LNG storage capacity or LNG stock in respect of which that Market Participant is the registered holder.
(i)	With effect from the commencement of the gas day on which a valid LNG storage transfer is expressed to take effect in accordance with clause 4.2.6(e)(3) the LNG stock which is the subject of a valid LNG storage transfer will be added to the transferee’s LNG stock and deducted from the transferor’s LNG stock.
(j)	If for any reason a Market Participant ceases to be entitled to any LNG storage capacity, the LNG Storage Provider will, as soon as reasonably practicable after it becomes aware of the cessation, register that fact. Any LNG storage transfer which is notified to the LNG Storage Provider will be valid and capable of registration, notwithstanding that the transferor’s entitlement to the LNG storage capacity which is the subject of the LNG storage transfer has ceased, unless and until the cessation has been registered.
4.2.7	Liquefaction of gas
(a)	Unless VENCorp otherwise approves, the LNG Storage Provider must order, in respect of each month, the maximum quantity of gas which it is entitled to require BOC to liquefy for storage in that month under the terms of the BOC Agreement.
(b)	The quantity of gas made available to BOC for liquefaction and storage in the LNG storage facility during each trading interval as a result of an order made by the LNG Storage Provider pursuant to clause 4.2.7(a) shall be allocated to, and be deemed to have been made available by, VENCorp or the Market Participants who hold LNG storage capacity in the following order of priority: 
(1)	first, such quantity of gas shall be allocated to, and be deemed to have been made available by, VENCorp as may be necessary to ensure that the LNG reserve is maintained at the maximum level and that there is sufficient LNG stock for use by BOC in accordance with the terms of the BOC Agreement; and
(2)	second, a proportion of the remaining quantity, if any, (after a quantity has been allocated to VENCorp pursuant to clause 4.2.7(b)(1)) shall be allocated to, and be deemed to be made available by, each Market Participant who holds LNG storage capacity in accordance with the following formula:
Q  =  QL   x    PAC

TAC
where:
Q	is the Market Participant’s allocation of the remaining quantity (if any) of gas made available to BOC for liquefaction and storage in a trading interval;
QL	is the remaining quantity of gas (if any) made available to BOC for liquefaction and storage in that trading interval;
PAC	is that Market Participant’s available LNG capacity at the start of that trading interval; and
TAC	is the sum of all Market Participants available LNG capacity at the start of that trading interval.
(c)	The LNG Storage Provider must determine the quantity of gas deemed to have been made available by VENCorp and each Market Participant to BOC for liquefaction during each trading interval and notify VENCorp of its determination as soon as reasonably practicable after the end of the relevant trading interval.
(d)	To avoid doubt, any quantity of gas deemed to have been made available by a Market Participant to BOC during a trading interval in accordance with this clause 4.2.7 is to be taken into account for the purpose of calculating that Market Participant’s trading imbalance in that trading interval.
4.2.8	Vaporisation of LNG and LNG injection offers
(a)	Each Market Participant must submit LNG injection offers in respect of the entire amount of its LNG stock for each trading interval. LNG injection offers must be unconditional and must not specify any minimum or maximum quantity of LNG stock.
(b)	VENCorp must not accept an LNG injection offer submitted by a Market Participant unless that Market Participant is the registered holder of sufficient available LNG stock to enable it to satisfy that LNG injection offer.
(c)	Subject to clause 4.2.8(d), VENCorp must schedule LNG injection offers in accordance with the provisions of clause 3.1.
(d)	VENCorp must call on LNG injection offers by issuing scheduling instructions directly to the LNG Storage Provider and, to avoid doubt, VENCorp is not required to issue scheduling instructions to Market Participants in respect of their LNG injection offers.
(e)	To avoid doubt, LNG stock held by Market Participants will only be vaporised in accordance with the LNG injection offers submitted by them and such Market Participants have no right to submit nominations in respect of the injection of vaporised LNG into the transmission system or any other right in respect of the withdrawal of LNG stock from storage.
4.2.9	LNG Reserve
(a)	VENCorp may utilise the LNG reserve by requiring the LNG Storage Provider to vaporise LNG stock held by the LNG Storage Provider on its behalf at such times and in such quantities as VENCorp may reasonably consider necessary or desirable to ensure the security of the transmission system and to satisfy VENCorp’s operational requirements.
(b)	The LNG Storage Provider must comply with all reasonable directions of VENCorp relating to the utilisation of the LNG reserve, including any direction to vaporise any LNG stock which comprises part of the LNG reserve.
(c)	Subject to clauses 4.2.2(b) and (c), at intervals not exceeding two years, VENCorp must review the LNG reserve and this clause 4.2 to establish:
(1)	whether it is sufficient to enable VENCorp to meet its operational requirements and to ensure the security of the transmission system;
(2)	whether the basis for allocating LNG storage capacity should be changed;
(3)	whether Market Participants should be granted liquefaction or vaporisation rights which are more flexible or different to the liquefaction and vaporisation rights conferred by this clause 4.2; and
(4)	whether there should be any other change in the way in which the LNG storage facility is utilised.
(d)	VENCorp must consult with Market Participants and the LNG Storage Provider for the purpose of carrying out any review of the LNG reserve and this clause 4.2 pursuant to clause 4.2.9(c).
(e)	The LNG Storage Provider and the Market Participants who hold LNG storage capacity must take such action and do such things as VENCorp may reasonably require to give effect to any recommendation made by VENCorp relating to the LNG reserve or this clause 4.2 as a result of any review carried out by VENCorp pursuant to clause 4.2.9(c).
(f)	Any gas which is vaporised for testing of the LNG facility and boil off gas is to be treated as having been taken from the LNG reserve and included in the linepack account.
4.2.10	Provision of information
(a)	The LNG Storage Provider and VENCorp must establish and operate an information exchange system allowing the electronic transfer of information between the LNG Storage Provider and VENCorp relating to the LNG storage facility.
(b)	The specifications and requirements of the information exchange system referred to in clause 4.2.10(a) shall be as agreed between the LNG Storage Provider and VENCorp from time to time (such agreement not to be unreasonably withheld or delayed) and the cost of providing and maintaining that system shall be borne by the LNG Storage Provider and VENCorp in such proportions as they may agree from time to time (such agreement not to be unreasonably withheld or delayed).
(c)	The information exchange system referred to in clause 4.2.10(a) must allow VENCorp to have access to the following information as soon as reasonably practicable after the end of each trading interval:
(1)	the quantity of gas which was made available to BOC for liquefaction during the previous trading interval;
(2)	the quantity of LNG stock which is held in the LNG storage facility at the end of the previous trading interval for use by BOC, VENCorp and each Market Participant who holds LNG storage capacity (after taking account of any gas made available for liquefaction by VENCorp and each Market Participant pursuant to clause 4.2.7(b) and liquefied during that trading interval and any LNG vaporised during that trading interval as a result of any scheduling instructions or any other direction by VENCorp); 
(3)	the quantity of gas which was made available to BOC for use in its LNG plant and air separation, nitrogen liquefaction, storage and other facilities and returned to the transmission system during the previous trading interval; and
(4)	such other information relating to the operation of the LNG storage facility as VENCorp may reasonably require.
(d)	VENCorp must, if requested by a Market Participant who holds LNG storage capacity, make available to that Market Participant the following information relating to that Market Participant (if and to the extent that such information is available to VENCorp):
(1)	the quantity of gas which was deemed to be made available by that Market Participant to BOC for liquefaction during each trading interval;
(2)	the quantity of LNG stock held by the LNG Storage Provider on behalf of the Market Participant at the end of each trading interval; and
(3)	the quantity of LNG vaporised on behalf of the Market Participant during each trading interval.

4.3	GAS QUALITY

4.3.1	Principles
(a)	The quality specifications for gas which is delivered into the transmission system shall be the uniform gas quality specifications prescribed by the Gas Quality Regulations, unless VENCorp determines otherwise.
(b)	VENCorp is responsible for ensuring that any gas which is transferred from the transmission system to a distribution pipeline at a system withdrawal point complies with the prescribed specifications.
(c)	VENCorp has the sole right to accept delivery of off-specification gas.
(d)	Each Participant must use its reasonable endeavours to ensure that any gas which it injects or tenders for injection into the transmission system at a system injection point complies with the gas quality specifications for that system injection point.
(e)	Gas quality monitoring is required at all system injection points and such other points on the transmission system as VENCorp may consider necessary or desirable to enable VENCorp to monitor the quality of gas injected into and withdrawn from the transmission system.
4.3.2	Gas quality standards at injection points
(a)	VENCorp may approve, in relation to a system injection point, a gas quality standard which is different to the prescribed specifications and accept delivery of gas at that system injection point which complies with that gas quality standard if:
(1)	all of the Market Participants who propose to inject gas which does not comply with the prescribed specifications into the transmission system at that system injection point have entered into a written contract:
(A)	with one or more of the Market Participants who inject gas which complies with the prescribed specifications into the transmission system at another system injection point regarding the acceptance of the proposed gas quality standard at the system injection point first referred to in this clause 4.3.2(a); or
(B)	with a provider of gas processing services relating to the processing of the gas which does not comply with the prescribed specifications after that gas has been injected into the transmission system; and
(2)	VENCorp approves that contract and is satisfied that under the terms of the contract gas which complies with that gas quality standard can be co-mingled with other gas in the transmission system or processed so that: 
(A)	gas transferred from the transmission system to each distribution pipeline at a system withdrawal point will, notwithstanding acceptance of gas which complies with that gas quality standard,  comply with the prescribed specifications; and
(B)	gas transferred from the transmission system to each Transmission Customer will, notwithstanding acceptance of gas which complies with that gas quality standard, comply with the gas quality standards agreed between VENCorp and each Transmission Customer in respect of its transmission delivery point.
(b)	If at any time VENCorp considers that any contract which it has approved pursuant to clause 4.3.2(a) is not being complied with in any respect or that the conditions specified in clause 4.3.2(a)(2) can no longer be satisfied in respect of gas which is the subject of any such contract:
(1)	VENCorp must notify each Market Participant who injects gas into the transmission system at the relevant system injection point that the gas quality standard approved by VENCorp pursuant to clause 4.3.2(a) in respect of that system injection point is no longer approved and specify a time with effect from which gas injected into the transmission system at that system injection point must comply with the prescribed regulations;
(2)	each Market Participant must not, at any time after the time specified in the notice referred to in clause 4.3.2(b)(1), inject gas, or tender gas for injection, at the relevant system injection point which does not comply with the prescribed specifications; and 
(3)	VENCorp may refuse to accept gas into the transmission system at the relevant system injection point which does not comply with the prescribed specifications.
(c)	Subject always to clauses 4.3.2(a) to (b) (inclusive), VENCorp may approve, in relation to a transmission delivery point, a gas quality standard which is different from the prescribed specifications if that gas quality standard has been agreed by all Participants who withdraw gas at that transmission delivery point.
4.3.3	Gas quality monitoring
(a)	A gas quality monitoring system must: 
(1)	be provided by the Transmission Pipeline Owner at each system injection point and such other points on the transmission system as VENCorp may consider necessary or desirable to enable VENCorp to monitor the quality of gas injected and withdrawn from the transmission system; and
(2)	be paid for by the Transmission Pipeline Owner, unless otherwise agreed by the Transmission Pipeline Owner and the Connected Party associated with that monitoring point.
(b)	The gas quality monitoring system must be approved by VENCorp. 
(c)	The gas quality monitoring system must provide for the continuous measurement of gas quality and the continuous transmission of gas quality data in real time to the metering database unless VENCorp agrees that, having regard to the characteristics of the particular monitoring point, satisfactory measurement can be achieved by sampling or some means other than continuous measurement.
(d)	The gas quality monitoring system must include the following equipment:
(1)	a gas chromatograph for determination of gas composition, heating value, relative density and wobbe index;
(2)	an oxygen analyser for determination of the oxygen content;
(3)	a sulphur analyser for determination of hydrogen-sulphide and total sulphur; and
(4)	a water analyser,
unless VENCorp agrees otherwise, having regard to alternate measuring methods or the characteristics of the particular gas supply.
(e)	The provider of a gas quality monitoring system must ensure that, at its own cost, data from the gas quality monitoring system is transmitted to the metering database in a form and manner compatible with the metering database.
(f)	The provider of the gas quality monitoring system must submit to VENCorp for approval a plan to ensure the accuracy and reliability of the gas quality monitoring system. The plan must include:
(1)	provision for the periodic testing and calibration of the gas quality monitoring system in accordance with standards approved by VENCorp;
(2)	procedures ensuring that the gas quality monitoring system will remain free from interference; and
(3)	provision for the storing of all data relating to the operation and calibration of the gas quality monitoring system.
(g)	The provider of the gas quality monitoring system must provide VENCorp and any other affected Participant with all data and information relating to gas quality at the monitoring point, including all test and calibration reports relating to the gas quality monitoring system, on request. The party requesting the information must pay the provider’s reasonable costs of providing that information.
4.3.4	Off-specification gas
(a)	Each Participant must use its reasonable endeavours to ensure that any gas which it injects or tenders for injection into the transmission system at a system injection point complies with the gas quality specifications for that system injection point.
(b)	If VENCorp is aware that off-specification gas is being, or is likely to be, or has been injected by a Participant at a system injection point, VENCorp may refuse to accept delivery or continued delivery of all or some of the off-specification gas for such period as VENCorp may determine. 
(c)	VENCorp must not refuse to accept, on quality grounds, delivery of gas at a system injection point which complies with the gas quality specifications for that system injection point.
(d)	Each Participant must notify VENCorp as soon as it becomes aware that gas which does not comply with the gas quality specifications is being, or is likely to be, or has been delivered at a system injection point. Any such notification must include all information which is available to the Participant in respect of the off-specification gas, including each aspect of each specification with which it fails to comply, the degree of its failure to comply and the likely time at which the Participant will be able to resume delivery of gas in accordance with the gas quality specifications.
(e)	VENCorp may accept delivery of off-specification gas if, in the reasonable opinion of VENCorp: 
(1)	acceptance is necessary to ensure the safety of the public or the security of the transmission system; or
(2)	off-specification gas can be co-mingled with other gas in the transmission system or processed so that: 
(A)	gas transferred from the transmission system to each distribution pipeline at a system withdrawal point will, notwithstanding acceptance of that off-specification gas, comply with the prescribed specifications; and
(B)	gas transferred from the transmission system to each Transmission Customer will, notwithstanding acceptance of that off-specification gas, comply with the gas quality standards agreed between VENCorp and each Transmission Customer in respect of its transmission delivery point.
(f)	If VENCorp accepts or intends to accept any off-specification gas in accordance with clause 4.3.4(e), it must promptly give notice of that fact to each Participant who VENCorp reasonably believes is likely to be affected by gas which does not comply with the prescribed specifications or the gas quality standard agreed by VENCorp in respect of a transmission delivery point and, so far as known, the extent to which gas is likely to fail to comply with the prescribed specifications or such gas quality standard and the likely quantity and duration of such off specification gas.

4.4	METERING

4.4.1	Introduction to the metering rules
(a)	This clause 4.4 applies to the following Participants:
(1)	Producers; 
(2)	Transmission Pipeline Owners;
(3)	Interconnected Pipeline Owners;
(4)	Distributors;
(5)	Retailers;
(6)	Transmission Customers; and
(7)	Market Customers.
(b)	This clause 4.4 sets out the metering requirements for connection points on the transmission system  and distribution delivery points at which gas is withdrawn by Market Customers.
(c)	The purpose of this clause 4.4 is to set out the rights and obligations of the Participants described in clause 4.4.1(a) relating to the measurement of volumes and quantities of gas and the provision of data for the operation of the market.
(d)	This clause 4.4 sets out provisions relating to:
(1)	metering installations used for the measurement of volumes and quantities of gas;
(2)	the provision, installation and maintenance of metering equipment;
(3)	the accuracy of metering equipment;
(4)	metering calibration requirements;
(5)	the provision of metering data for the purpose of settlements;
(6)	the security of, and rights of access to, metering data; and
(7)	standards of performance of metering installations.
(e)	The key principles adopted in this clause 4.4 are:
(1)	each: 
(A)	connection point on the transmission system; and
(B)	distribution delivery point at which gas is withdrawn by a Market Customer and required to be measured for settlement purposes,
must have a metering installation;
(2)	subject to clause 4.4.1(e)(3), costs associated with a metering installation are to be borne by the responsible person, provided that the responsible person may agree with an affected Participant, either generally or in any particular case, that those costs are instead to be borne (in whole or in part) by that affected Participant;
(3)	subject to any agreement to the contrary, the reasonable costs associated with:
(A)	new metering installations;
(B)	modifications to existing metering installations; or
(C)	decommissioning of metering installations,
are to be borne by the affected Participant to the extent that those costs arise from new, increased or reduced gas demand of, or supply to, that affected Participant, unless the Regulator otherwise determines either generally or in any particular case;
(4)	the responsible person must ensure that the accuracy of the metering installation complies with the standards prescribed in this clause 4.4;
(5)	the accuracy of the metering installation at each metering point is to be determined by reference to the volume of gas passing through that metering point;
(6)	metering installations must be:
(A)	secure;
(B)	registered with VENCorp; 
(C)	capable of providing metering data for transmission to the metering database; and
(D)	installed, connected, commissioned, operated, checked and maintained in accordance with this clause 4.4 and in accordance with any applicable laws;
(7)	metering installations must be capable of recording metering data in trading intervals;
(8)	the responsible person must calibrate its metering installations in accordance with clause 4.4.9;
(9)	quantities of gas are to be quantified by reference to their energy content and stated in units of joules;
(10)	the electronic accessibility of each metering installation must be co‑ordinated by the responsible person to prevent congestion;
(11)	VENCorp is responsible for creating, maintaining and administering the metering database;
(12)	Participants are entitled to access to the metering database in respect of their own injections or withdrawal of gas;
(13)	each Transmission Pipeline Owner is entitled to access metering data in respect of metering points on its pipeline;
(14)	each Interconnected Pipeline Owner is entitled to access metering data in respect of a metering point at a transfer point at which its transmission pipeline is connected;
(15)	each Distributor is entitled to access metering data in respect of metering points on its pipeline and metering points at connection points between the transmission system and its pipeline;
(16)	metering data used in settlement statements is to be validated in accordance with clause 4.4.24;
(17)	other meters may be installed by and at the expense of an affected Participant and used to check metering installations;
(18)	VENCorp must maintain metering data which is transmitted from metering installations to the metering database:
(A)	for sixteen months in accessible format; and
(B)	for seven years in archive; and
(19)	VENCorp must establish a registration process to facilitate the application of this clause 4.4 to Participants in respect of:
(A)	new metering installations;
(B)	modifications to existing metering installations; and
(C)	decommissioning of metering installations.
4.4.2	Obligations of Participants to establish metering installations
(a)	Before a Participant will be permitted by VENCorp to inject gas into or withdraw gas from a connection point on the transmission system or a transfer point or be permitted to participate in the market in respect of a connection point on the transmission system:
(1)	that connection point must have a metering installation;
(2)	that metering installation must have been installed in accordance with this clause 4.4 and be accurate in accordance with clause 4.4.8; and
(3)	that metering installation must be registered with VENCorp.
(b)	VENCorp may refuse to permit a Participant to inject gas into or withdraw gas from a connection point on the transmission system if the metering installation at that connection point does not comply with the provisions or requirements of this clause 4.4.
(c)	Before a Market Customer will be permitted to participate in the market in respect of a distribution delivery point at which it takes delivery of gas:
(1)	that distribution delivery point must have a metering installation;
(2)	that metering installation must have been installed in accordance with this clause 4.4 and be accurate in accordance with clause 4.4.8; and
(3)	that metering installation must be registered by VENCorp.
(d)	VENCorp may refuse to permit a Market Customer to participate in the market in respect of a distribution delivery point if the metering installation at that distribution delivery point does not comply with the provisions of this clause 4.4.
(e)	Subject to any agreement to the contrary, VENCorp may refuse to permit a Market Participant to participate in the market if that Market Participant does not have in force an agreement with a responsible person whereby that Market Participant contributes to its proportionate share of the costs incurred by that responsible person in measuring and testing gas at all metering installations for which the responsible person is responsible and at which the Market Participant has gas injected.
(f)	In clause 4.4.2(e), and subject to any agreement to the contrary:
(1)	“proportionate share” means a share calculated having regard to the actual quantity of gas injected at the metering installation by that Market Participant against the total quantity of gas injected at that metering installation in any particular billing period; and
(2)	“costs” means the total costs incurred by the responsible person in operating the metering installation,
and for the avoidance of doubt, VENCorp may provide to a responsible person for use in calculating the proportionate share of costs pursuant to clause 4.4.2(e), any statement submitted to it by an Allocation Agent pursuant to clause 3.5.2.
4.4.3	Responsibility for metering installation
(a)	The person who is responsible for providing a metering installation is the responsible person.
(b)	Subject to clause 4.4.3(d), the responsible person for a metering installation at:
(1)	a receipt point on the transmission system is the Transmission Pipeline Owner associated with that receipt point, unless otherwise agreed between that Transmission Pipeline Owner and the Producer or the Storage Provider associated with that transfer point, as the case may be;
(2)	a transfer point between one transmission pipeline and another transmission pipeline is the Transmission Pipeline Owner or Interconnected Pipeline Owner whose pipeline is likely to deliver more gas to the other pipeline than it receives from that other pipeline in the year following connection, unless otherwise agreed between the Transmission Pipeline Owners and/or Interconnected Pipeline Owners associated with that transfer point;
(3)	a transfer point between the transmission system and a distribution pipeline is the Transmission Pipeline Owner associated with that transfer point unless otherwise agreed between that Transmission Pipeline Owner and the Distributor associated with that transfer point;
(4)	a transmission delivery point at which a Transmission Customer is connected is the Transmission Pipeline Owner associated with that transmission delivery point, unless otherwise agreed between that Transmission Pipeline Owner and that Transmission Customer; and
(5)	a distribution delivery point at which a Market Customer is connected is the Distributor associated with that distribution delivery point, unless otherwise agreed by that Distributor and the Market Customer.
(c)	The agreement of the relevant Participants under this clause must not be unreasonably withheld.
(d)	A person who is not a Participant may only be the responsible person for a metering installation if it agrees with VENCorp to be bound by this clause 4.4 and such other provisions of these Rules as VENCorp may require on such terms as VENCorp may reasonably require.
(e)	Where agreement is reached under clause 4.4.3(b), the person who would otherwise be the responsible person must immediately advise VENCorp of that agreement.
4.4.4	Other responsibilities of a responsible person
The responsible person must:
(a)	ensure that its metering installations are provided, installed and maintained in accordance with this clause 4.4 and all applicable laws;
(b)	ensure that the accuracy of each of its metering installations complies with the requirements of  clause 4.4.8; 
(c)	ensure that each of its metering installations is calibrated in accordance with clause 4.4.9;
(d)	if VENCorp requires, arrange for the provision of remote monitoring facilities to alert VENCorp or the responsible person of any failure of any components of the metering installation which might affect the accuracy of the metering data derived from that metering installation and, in the case of a facility which alerts the responsible person rather than VENCorp, the responsible person must notify VENCorp as soon as possible after the responsible person becomes aware of such failure; and
(e)	provide to VENCorp the information specified in schedule 4.2 for each of its metering installations.
4.4.5	Additional metering
Any affected Participant may at its own cost provide additional meters or similar equipment at or near a connection point on the transmission system or a distribution delivery point in addition to the metering installation provided by the responsible person at that connection point or distribution delivery point for the purposes of checking the metering data obtained from that metering installation or for any other purposes, provided that such equipment:
(a)	does not cause any Participant to breach any of the requirements of these Rules;
(b)	complies with all applicable laws; and
(c)	does not interfere with that metering installation or affect in any way the integrity or accuracy of the metering data provided by the metering installation.
4.4.6	Metering installation components
A metering installation must:
(a)	be accurate in accordance with clause 4.4.8;
(b)	have facilities to enable metering data to be transmitted from the metering installation to the metering database, and be capable of communication with the metering database, in accordance with clause 4.4.18;
(c)	contain a device which has a visible or an equivalently accessible display of metering data or which allows the metering data to be accessed and read at the same time by portable computer or other equipment of a type or specification reasonably acceptable to all persons who are entitled to have access to that metering data in accordance with clause 4.4.22(a);
(d)	be secure in accordance with clause 4.4.10;
(e)	have electronic data recording facilities such that all metering data can be measured and recorded in trading intervals;
(f)	be capable of separately registering and recording flows in each direction where bi-directional gas flows occur; and
(g)	have a meter having an internal or external data logger capable of storing the metering data for at least 35 days. 
4.4.7	Location of metering point
The responsible person must ensure that the metering installation is located as close as practicable to the connection point or distribution delivery point in relation to which the metering installation is being provided (taking into account, amongst other things, the cost of installation and security).
4.4.8	Meter accuracy
A metering installation must satisfy the uncertainty limits specified in schedule 4.1 over its entire range of flow rates.
4.4.9	Calibration of metering installations
(a)	This clause 4.4.9 applies only to metering installations at system points.
(b)	The responsible person must procure that its metering installations are calibrated in accordance with the requirements contained in schedule 4.1.
(c)	VENCorp must review the calibration requirements contained in schedule 4.1 within one year after the commencement date and at intervals not exceeding one year thereafter and may, following consultation with Market Participants, change such requirements. VENCorp must publish details of any such change and the date upon which the change will take effect.
(d)	The responsible person must establish calibration procedures in respect of each of its metering installations. The calibration procedures must comply with any requirements which VENCorp may from time to time determine.
(e)	VENCorp may check calibration results recorded in the metering database in respect of any metering installation and arrange for testing of metering installations in order to satisfy itself that the accuracy of each metering installation conforms with the requirements of this clause 4.4 or to determine the consistency between the data held in the metering database and metering data held in a metering installation.
(f)	The responsible person must make available the results of all tests in respect of its metering installations to VENCorp and all affected Participants as soon as practicable after they have been completed.
(g)	If there is an inconsistency between the data held in a metering installation and the data held in the metering database, the data in the metering installation is to be taken as prima facie evidence of the energy data derived from that metering installation.
(h)	The responsible person must permit VENCorp and any affected Participant to have a representative present to observe the calibration of its metering installations and any consequential adjustments.
(i)	The responsible person must give VENCorp and all affected Participants at least fourteen days written notice, or such shorter notice as may be agreed by VENCorp and all affected Participants, of the proposed hours and date or dates on which a metering installation is to be calibrated and the nature of the calibration to be undertaken.
(j)	Each affected Participant who wishes to have a representative present to observe a calibration of a metering installation must give written notice to the responsible person of its intention to have a representative present not less than seven days prior to the date on which that calibration is to be undertaken as specified in the notice referred to in clause 4.4.9(i). The responsible person and all affected Participants who wish to have a representative present must use all reasonable endeavours to agree upon the time and date at which the calibration will take place and, in the absence of agreement, the calibration will take place at the time specified in the notice given by the responsible person pursuant to clause 4.4.9(i).
(k)	If VENCorp or an affected Participant does not exercise its right under clause 4.4.9(h) to have a representative present, the results of the calibration will be binding on VENCorp and that affected Participant.
(l)	VENCorp and each affected Participant may, at all reasonable times, by giving reasonable prior notice to the responsible person:
(1)	inspect the responsible person’s metering installation and records in respect of a metering installation; and
(2)	require that the responsible person conduct a calibration of any metering equipment which VENCorp or the affected Participant reasonably believes is inaccurate.
(m)	The cost of any calibration which the responsible person is required to conduct pursuant to clauses 4.4.9(e) or 4.4.9(l) must be borne by the person requiring the calibration if the metering equipment is found to be accurate within the applicable accuracy parameters described in schedule 4.1 and by the responsible person if found to be outside any of those accuracy parameters.
(n)	The responsible person must monitor its metering installations on a regular basis in order to ensure that they are operating properly in accordance with this clause 4.4.
(o)	If the responsible person becomes aware that the accuracy of a metering installation does not comply with the requirements of this clause 4.4 or of any matter which could affect the integrity of the metering data, the responsible person must:
(1)	notify all affected Participants and VENCorp as soon as practicable after it becomes aware of the matter; and
(2)	arrange for the accuracy of the metering installation to be restored or for the metering installation to be modified or replaced by such time as VENCorp may reasonably determine so that the metering installation meets the requirements of this clause 4.4.
(p)	The responsible person must within two business days after it becomes aware of any matter described in clause 4.4.9(o) provide a report to VENCorp in relation to that matter and, where requested by VENCorp, prepare an estimate of the actual quantity of gas transferred through the affected metering installation.
(q)	The responsible person must notify all affected Participants and VENCorp if practicable at least seven days prior to, and in any event seven days after, any modification, adjustment, repair or replacement of any of its metering installations where such action may have an impact on metering accuracy or integrity and such notice must, if applicable, include a record of the readings of the relevant metering installation at all relevant times.
4.4.10	Security of metering equipment
(a)	The responsible person must use reasonable endeavours to protect the metering installation from unauthorised interference both intentional and inadvertent by providing secure housing for metering equipment or otherwise ensuring that security at the metering point is adequate to protect against such interference.
(b)	If evidence of tampering with a metering installation is found by a Participant, all affected Participants must be notified of that fact by that Participant as soon as reasonably possible.
(c)	If a Participant finds evidence that the accuracy of the metering of a metering installation might have been affected by any tampering, then the responsible person must test the metering installation to ensure that the metering equipment operates within the applicable accuracy parameters described in schedule 4.1.
(d)	A Participant who interferes with a metering installation without the approval of the responsible person must pay the responsible person its reasonable costs of adjustment, repair, replacement and testing of the metering installation.
4.4.11	Security of metering data held in a metering installation
(a)	The responsible person must ensure that metering data held in a metering installation is protected from local or remote electronic access by suitable security electronic access controls (including, if required by VENCorp, passwords).
(b)	The responsible person must keep secure records of electronic access passwords.
(c)	If required by VENCorp, the responsible person must allocate ‘read-only’ passwords for each metering installation to affected Participants and VENCorp, except where separate ‘read-only’ and ‘write’ passwords are not available, in which case the responsible person must allocate a password to VENCorp only.
(d)	The responsible person must hold ‘read-only’ and ‘write’ passwords.
4.4.12	Changes to metering parameters and settings
Changes to parameters or settings within a metering installation which may affect the accuracy of metering data must be:
(a)	notified to VENCorp by the responsible person at least two business days before the change (other than a change made as a result of a calibration carried out pursuant to this clause 4.4) is made;
(b)	confirmed to VENCorp by the responsible person within two business days after the change has been made; and
(c)	recorded by VENCorp in the metering register.
4.4.13	Energy metering and measurement
(a)	The responsible person must ensure that the metering installation is capable of determining quantities of gas and where relevant the energy content of volumes of gas flowing through the relevant metering point in accordance with this clause 4.4.13.
(b)	A metering installation at a connection point on the transmission system must be capable of determining the energy content of quantities of gas flowing through the metering point unless otherwise agreed by VENCorp and the responsible person.
(c)	A metering installation at a distribution delivery point must be capable of measuring the volume of gas flowing through the metering point unless VENCorp reasonably requires that metering installation also to be capable of determining the energy content of quantities of gas flowing through the metering point.
(d)	For avoidance of doubt, where a metering installation measures only the volume of gas flowing through the metering point, the determination of the energy content of the quantities of gas flowing will be done within the metering database.
(e)	The energy content of quantities of gas flowing through a metering point at each metering installation whether calculated within the metering installation or within the metering database must be calculated in accordance with American Gas Association Report no. 7 (measurement of gas by turbine meters), American Gas Association Report no. 8 (compressibility factors of natural gas and other related hydro-carbon gas) and ISO6976 (calculation of calorific value, density, relative density and wobbe index from gas composition) unless the responsible person, the affected Participants and VENCorp agree otherwise.
(f)	Where the energy content of quantities of gas flowing through a metering point is calculated within a metering installation it must be calculated using data collected from the metering installation or, if the data is not available from the metering installation, using data transmitted to the metering installation from the metering database.
(g)	The source of data used for determining the energy content of gas flowing through a metering point at a metering installation (including heating value, gas composition and relative density) must be determined by VENCorp, after consultation with the responsible person.
(h)	In determining the appropriate source of data which VENCorp must make available to the responsible person to enable the responsible person to calculate the energy content of quantities of gas in accordance with this clause 4.4.13, VENCorp must have regard to the proximity of the source of the data to the relevant metering installation.
(i)	In determining the heating values to be applied to the calculation of the energy content of quantities of gas, VENCorp must use reasonable endeavours to ensure that the uncertainty limits specified in schedule 4.1 are satisfied.
(j)	Unless VENCorp and the responsible person agree otherwise, data made available by VENCorp to the responsible person for the purpose of calculating the energy content of quantities of gas flowing through a metering point must be averaged for one hour and applied by the responsible person for the purpose of measuring the energy content of quantities of gas flowing through the metering point in the next hour.
(k)	Each metering installation must be capable of recording metering data in trading intervals unless it is agreed by VENCorp and the affected Participants that metering data may be recorded in intervals of time which are shorter than a trading interval.
4.4.14	Performance of metering installations
(a)	The responsible person must use all reasonable endeavours to procure that metering data is able to be transmitted to the metering database from its metering installations:
(1)	within the applicable accuracy parameters described in schedule 4.1;
(2)	within the time required for settlement, at a level of availability of at least 99% per annum in the case of metering installations (excluding the communication link); and 
(3)	within the time required for settlement, at a level of availability of at least 95% per annum in the case of the communication link,
or as otherwise agreed between VENCorp and the responsible person.
(b)	If a metering installation malfunction or defect occurs, the responsible person must procure that repairs must be made to the metering installation as soon as practicable and in any event within two days, unless VENCorp otherwise agrees.
(c)	A Participant who becomes aware of a metering installation malfunction or other defect must advise VENCorp as soon as practicable.
4.4.15	Meter Time
(a)	The responsible person must ensure that all metering installation and data logger clocks are referenced to Australian Eastern Standard Time.
(b)	The metering database must be set within an accuracy of plus or minus two seconds of Australian Eastern Standard Time for a system point other than a transmission delivery point and within an accuracy of plus or minus five seconds of Australian Eastern Standard Time for a transmission delivery point and a distribution delivery point.
4.4.16	Pulse output facilities
(a)	Within a reasonable time of being requested by an affected Participant or VENCorp, the responsible person must provide pulse outputs representing the quantities of gas measured for use by the affected Participant in controlling its production or consumption of gas or by VENCorp for any system operation purpose.
(b)	The person requesting the pulse output under clause 4.4.16(a) must pay the responsible person’s reasonable costs relating to the provision of the pulse output.
4.4.17	Changes to metering data
The responsible person must not make, and must use reasonable endeavours to ensure that no other person makes, any alteration to the original stored data in a metering installation.
4.4.18	Data transfer and collection
(a)	VENCorp must collect metering data from all metering installations from which metering data is required for settlement purposes unless otherwise agreed by VENCorp and the affected Market Participants.
(b)	Each Participant must use its reasonable endeavours to ensure that VENCorp is given access to, or is provided with, the metering data referred to in clause 4.4.18(a).
(c)	The responsible person must, at its own cost, ensure that metering data derived from a metering installation for which it is responsible shows the time and date at which it is recorded and is capable of being transmitted from the metering installation to the metering database in accordance with VENCorp’s reasonable requirements and in accordance with VENCorp’s metering communications procedures.
(d)	Without prejudice to the generality of clause 4.4.18(c), the responsible person must ensure that each of its metering installations contains a telephone line or radio transmitter and/or such other equipment as VENCorp may reasonably require to enable metering data to be transmitted to, and to enable VENCorp to obtain remote access to the metering data from, the metering database.
4.4.19	Installation databases
(a)	The responsible person must create, maintain and administer an installation database in relation to all its metering installations.
(b)	The responsible person must ensure that each affected Participant and VENCorp is given access to the information specified in clause 4.4.19(c) in its installation database at all reasonable times and:
(1)	in the case of data sixteen months old or less, within two business days of receiving written notice from the person seeking access; and
(2)	in the case of data more than sixteen months old, within thirty days of receiving written notice from the person seeking access.
(c)	The responsible person must ensure that its installation database contains the information specified in schedule 4.3.
(d)	The responsible person must ensure that the information specified in clause 4.4.19(c) is stored in its installation database:
(1)	in accessible format for sixteen months; and
(2)	in archive, for seven years or for the life of the relevant meter, whichever is longer.
4.4.20	 Metering database
(a)	VENCorp must create, maintain and administer a metering database containing information for each metering installation registered with VENCorp.
(b)	VENCorp may appoint an agent from time to time to create, maintain and administer the metering database.
(c)	VENCorp must use its reasonable endeavours to procure that the metering database is accessible by all affected Participants at all reasonable times and:
(1)	in the case of data sixteen months old or less, within four hours of receiving a written request from an affected Participant; and
(2)	in the case of data more than sixteen months old, within two business days of receiving a written request from an affected Participant.
(d)	The metering database must include metering data, energy data, energy calculations, gas quality data, data substituted in accordance with this clause 4.4 and all calculations made for settlement purposes.
(e)	Data must be stored in the metering database:
(1)	for 16 months in accessible format; and
(2)	for 7 years in archive.
(f)	Rights of access to data held in the metering database are set out in clause 4.4.22.
4.4.21	Register of metering information
(a)	As part of the metering database, VENCorp must maintain a metering register of all metering installations which provide metering data used by VENCorp for settlement purposes.
(b)	The metering register referred to in clause 4.4.21(a) must contain the information specified in schedule 4.2. 
(c)	If the information in the metering register indicates that a metering installation does not comply with the requirements of this clause 4.4: 
(1)	VENCorp must advise all affected Participants and the responsible person of that fact; and 
(2)	the responsible person must procure that the metering installation complies with the requirements of this clause 4.4 within two business days after the date of the notice unless otherwise agreed by VENCorp.
(d)	Prior to the group of customers referred to in section 6B(1)(d) of the Gas Industry Act ceasing to be Franchise Customers, VENCorp must, in accordance with the public consultation procedures, establish, administer, and review transfer procedures to deal with registration procedures for Non-Franchise Customers transferring between Retailers. 
(e)	VENCorp is not obliged to accept registration data in relation to a Non-Franchise Customer transferring between Retailers if such registration data is not provided in accordance with the Non-Franchise Customer transfer procedures referred to in clause 4.4.21(d). 
4.4.22	Rights of access to metering data
(a)	The only persons entitled to have either direct or remote access to metering data from a metering installation, the metering database or the metering register in relation to a metering point are:
(1)	each Market Participant whose settlement amounts are determined by reference to quantities of gas flowing through that metering point;
(2)	the responsible person who is responsible for the metering installation at that metering point;
(3)	a Transmission Pipeline Owner or Interconnected Pipeline Owner whose pipeline is connected to the metering installation at that metering point;
(4)	the Distributor whose pipeline is connected to the metering installations at that metering point; 
(5)	VENCorp and its authorised agents; and
(6)	the Allocation Agent appointed in respect of a system injection point or a system withdrawal point to which that metering point relates. 
(b)	Notwithstanding clause 4.4.22(a), a Transmission Customer is entitled to have either direct or remote access to metering data from a metering installation at a transmission delivery point for that Transmission Customer. 
(c)	Provided that the relevant Customer has consented, a Retailer is entitled to have access to historical data relating to a Customer who has transferred to that Retailer from another Retailer in relation to the period prior to the date on which that Customer transferred to that Retailer. 
(d)	Electronic access to metering data from a metering installation shall only be provided where passwords are allocated in accordance with clause 4.4.11 otherwise access to metering data shall be from the metering database.
(e)	The responsible person must ensure that access to metering data from the metering installation by persons referred to in clause 4.4.22(a) is scheduled appropriately to ensure that congestion does not occur.
(f)	The responsible person must ensure that all persons referred to in clause 4.4.22(a) have access to the metering data provided by its metering installations at all reasonable times and on reasonable notice.
(g)	If remote access is unavailable for a period of five consecutive business days, the responsible person must, if requested by any person referred to under clause 4.4.22(a), at its own cost, obtain readings locally from the metering installation and provide those readings to all persons with rights of access under clause 4.4.22(a).
4.4.23	Payment for access to metering data
All reasonable costs (including, without limitation, telecommunications charges) incurred by the responsible person in providing access to metering data at a metering installation or by VENCorp in providing access to information in the metering database must be paid by the Participant to whom the metering data or information was provided.
4.4.24	Data validation and substitution
(a)	VENCorp is responsible for the validation and substitution of metering data.
(b)	VENCorp must develop data validation processes in consultation with Participants.
(c)	If VENCorp detects a loss of metering data or incorrect metering data from a metering installation, it must notify all affected Participants of the fact and of details of the loss or error detected as soon as reasonably practicable and in any event at the time the next settlement statement is issued in respect of that metering point.
(d)	If:
(1)	any metering equipment at a metering installation is removed from service; or
(2)	any metering data is found to be inaccurate or incorrect; or
(3)	calibration of any meter at a metering installation reveals a measurement error which exceeds the metering substitution threshold applicable to that meter; or
(4)	calibration of any meter at a metering installation reveals a measurement error which is less than the metering substitution threshold  applicable to that meter and, in VENCorp’s reasonable opinion, a Participant would be materially and adversely affected if no substitution was made pursuant to this clause; or
(5)	metering data is not transmitted from a metering installation to the metering database within the time required for settlement,
VENCorp must adopt substitute readings in accordance with this clause 4.4.24.
(e)	If substituted readings are required pursuant to clauses 4.4.24(d)(3) or (4) and VENCorp is not aware of the time at which the error arose, then the substitution must be made for the period which is the shorter of:
(1)	the period from the time half-way between the time of the most recent calibration which demonstrated that the meter complied with the requirements of this clause 4.4 and the time when the error was corrected; and
(2)	the period commencing on the date six months prior to the date on which the error was corrected; and
(3)	such other period expiring on the date on which the error was corrected, being a period of less than six months, which VENCorp considers to be fair and reasonable.
(f)	If VENCorp is required to make  substituted readings pursuant to clause 4.4.24(d), VENCorp must:
(1)	determine the period of substitution (in accordance with clause 4.4.24(e) if applicable);
(2)	calculate the substituted readings in accordance with clause 4.4.24(h);
(3)	replace all readings derived from the relevant metering equipment during such period of substitution with such substituted readings; and
(4)	notify all affected Participants as soon as reasonably practicable after the substitution has been completed.
(g)	If an affected Participant disputes a substitution made by VENCorp pursuant to this clause 4.4.24, the following provisions apply:
(1)	the affected Participant must give notice of the dispute and the matters dispute to VENCorp;
(2)	as soon as reasonably practicable after receiving a notice pursuant to paragraph (1), VENCorp must give notice of the dispute and the matters disputed to each affected Participant;
(3)	the affected Participants must use their reasonable endeavours to resolve the dispute and agree the substituted readings; and
(4)	if the dispute has not been resolved by the affected Participants on or before the second business day prior to the next date on which VENCorp is required to issue final statements, VENCorp must use the substituted readings determined by it pursuant to clause 4.4.24(i) and the dispute must be referred to the Adviser for resolution in accordance with clause 7.2.
(h)	If substituted readings are required pursuant to this clause 4.4.24, they must be determined in the following order of priority:
(1)	if and to the extent that the responsible person is able to provide actual readings from the relevant meter for the period of substitution by manually reading the meter, those readings must be used for the purposes of determining the substituted readings;
(2)	if and to the extent that meter readings are available from another meter provided for the purposes of checking metering data pursuant to clause 4.4.5 and that meter complies with the accuracy requirements for the related metering installation, those readings must be used for the purposes of determining the substituted readings; and
(3)	if and to the extent that meter readings are not available in accordance with clauses 4.4.24(h)(1) and (2), VENCorp may use any or all of the following methods for providing data for the purposes of determining the substituted readings:
(A)	VENCorp may use readings available from any other meter which may reflect the flow of gas through the relevant metering point, whether or not such meter complies with the requirements of this clause 4.4;
(B)	VENCorp may use trend data recorded by VENCorp, the responsible person or any other affected Participant where, in VENCorp’s reasonable opinion, such data gives a good approximation of the actual measurement;
(C)	VENCorp may correct the reading which is required to be substituted if the deviation from the accurate reading is ascertainable by calibration or mathematical calculation; 
(D)	VENCorp may estimate readings based upon readings from the same meter under similar conditions during a period when the meter was registering accurate readings; or
(E)	VENCorp may use such other method as VENCorp may consider fair and reasonable in the circumstances.
4.4.25	Confidentiality
Metering data and passwords are confidential and each Participant must ensure that they are treated as confidential information in accordance with these Rules.
4.4.26	Use of meters
(a)	Metering data must be used by VENCorp as the primary source of data for settlement purposes.
(b)	Notwithstanding any other provision of this clause 4.4, VENCorp shall not be liable to any person in respect of any inaccuracies, discrepancies or other defects in metering data, including metering data which is stored in the metering database.
(c)	Where a metering installation is used for purposes in addition to the provision of metering data to VENCorp then:
(1)	that use must not be inconsistent with, or cause any Participant to breach, any requirements of these Rules or any applicable laws; and
(2)	the responsible person must coordinate with the persons who use the metering installation for such other purposes to ensure that clause 4.4.26(c)(1) is complied with.
4.4.27	Evolving technologies and processes and development of the market
Evolving technologies or processes that:
(a)	meet or improve the performance and functional requirements of this clause 4.4; or
(b)	facilitate the development of the market,
may be used in relation to a metering installation if agreed between the affected Participants and VENCorp (such agreement not to be unreasonably withheld).
4.4.28	Review of the metering provisions
No later than two years after the commencement date and at intervals not exceeding two years thereafter, VENCorp must undertake a review of the provisions of clause 4.4 in accordance with the public consultation procedures, including but not limited to:
(a)	new technologies and the impact of new technologies on and in relation to technical standards for metering in these Rules; 
(b)	contestability in the type of meters used; and
(c)	whether the provisions of clause 4.4 have the effect of eliminating the use of alternative types of meters.

SCHEDULE 4.1
METERING UNCERTAINTY LIMITS AND CALIBRATION REQUIREMENTS
1.	Uncertainty limits for measuring volume
The table below sets out the uncertainty limits required to be met by the responsible person for metering installations for transfer points on the transmission system. 

Category	Flow rate range(scmh)	Uncertainty limits (volume)	
A	>300,000	0.7%	
B	>40,000
300,000	1.0%	
C	>4,000
40,000	1.5%	
D	4,000	2.5%	

2.	Calibration requirements
The table below sets out the frequency with which the calibration must be carried out by the responsible person.

Category	A	B	C	D	
Peak flow rate (scmh)	300,000	40,000
300,000	4,000
40,000	4,000	
Minimum pressure and temperature transmitter calibration frequency	Quarterly	Six-monthly	Annually	Annually or as otherwise agreed with VENCorp	
Remote meter fault detection surveillance frequency	Daily by exception	Daily by exception	Daily by exception	Daily by exception	
In situ meter proving frequency	Annually
Note: for ultrasonic meters by electronic means	Annually
Note: for ultrasonic meters by electronic means	Annually or as otherwise agreed with VENCorp. Note: for ultrasonic meters by electronic means	Annually or as otherwise agreed with VENCorp	

3.	Uncertainty limits for energy calculations
The table below sets out the uncertainty limits required to be achieved in calculating energy values at transfer points on the transmission system. These limits have been developed to be applicable to a market based on a daily trading interval. Should the market adopt a different trading interval, these limits will need to be reviewed.

Category	Flow rate range(scmh)	Uncertainty limits
(energy)	
A	>300,000	1.0%	
B	>40,000
300,000	1.5%	
C	>4,000
40,000	2.0%	
D	4,000	3.0%	

SCHEDULE 4.2
METERING REGISTER

1.	General
(a)	The metering register forms part of the metering database and holds metering information relating to metering installations.
(b)	The purpose of the metering register is to facilitate:
(1)	the registration of system points, distribution delivery points, metering points and affected Participants;
(2)	the verification of compliance with these Rules; and
(3)	the audit flow of changes to the registered information.
2.	Metering register information
Metering information to be contained in the metering register should include such information as VENCorp considers reasonably necessary and by way of example, may include the following:
(a)	Meter identification:
(1)	metering installation reference number (MIRN);
(2)	logical meter identification - if a logical meter; and 
(3)	logical meter algorithm - if a logical meter.
(b)	Location in market:
(1)	CTM group identification;
(2)	heating value zone;
(3)	UAFG zone;
(4)	pricing zone;
(5)	system withdrawal zone;
(6)	injection point;
(7)	TUoS zone;
(8)	hub identification;
(9)	hub flow direction; and 
(10)	transmission or distribution connection point identification.
(c)	Associated parties:
(1)	metering data agency identification;
(2)	responsible person identification;
(3)	Market Participant settling account identification;
(4)	host Retailer identification;
(5)	supplying Retailer identification;
(6)	relevant Distributor identification and 
(7)	Allocation Agent identification.
(d)	Data validation and substitution processes agreed between affected Participants, including:
(1)	algorithms;
(2)	data comparison techniques
(3)	processing and alarms; and 
(4)	alternate data sources. 

SCHEDULE 4.3
INSTALLATION DATABASE

Each installation database must contain the following installation information and such other installation information as specified by VENCorp:
(a)	Metering point reference details, including:
(1)	locations and reference details (eg drawing numbers);
(2)	site identification names;
(3)	details of affected Participants associated with the system point; and 
(4)	the responsible person.
(b)	The identity and characteristics of metering equipment including:
(1)	serial numbers;
(2)	metering installation identification name;
(3)	metering installation types and models;
(4)	current test and calibration programme details, test results and references to test certificates;
(5)	calibration tables, where applied to achieve metering installation accuracy; and 
(6)	data register coding details.
(c)	Data communication details, including:
(1)	telephone number(s) (or frequency details in the case of telemetric equipment) for access to data;
(2)	communication equipment type and serial numbers;
(3)	communication protocol details or references;
(4)	data conversion details;
(5)	user identifications and access rights; and 
(6)	“write” password (to be contained in a hidden or protected field).