Decision

Application for amendment

Access Arrangement by Victorian Energy Networks Corporation
for the Principal Transmission System

Date: 2 August 2000

	File No:	Commissioners:
	CR97/159	Fels
		Asher
		Cousins
		Martin
		Jones
		Bhojani

1.	The application
On 28 June 2000 the Australian Competition and Consumer Commission (the Commission) received an application from the Victorian Energy Networks Corporation (VENCorp) for amendment of its Access Arrangement for the Principal Transmission System (PTS).  The application was submitted under the National Third Party Access Code for Natural Gas Pipeline Systems as it applies in Victoria (National Access Code).
The application for amendment relates to proposed changes to the Market and System Operations Rules (proposed Rule Changes).  These proposed Rule Changes appear in Annexure A to this decision, and are outlined below.
•	Clause 4.1.7(f) is to be amended to include obligations on VENCorp to develop and publish guidelines for approving or rejecting proposed connections.
•	Clause 4.4 is to be amended to provide consistency between the metering requirements in the MSOR and a decision by the Office of the Regulator General (the Office) regarding implementation of retail contestability.
•	Clause 3.7 is to be amended as a result of the changes to the metering requirements.  This includes amendments to clause 3.7.8(c)(2) to provide VENCorp with the ability to adjust the basis for setting trading limits and clause 3.7.9(c)(2)(B) to modify the requirement on VENCorp to undertake daily monitoring based on actual metered data.
•	‘Data logger’ is included as a new glossary term in Chapter 11.
2.	Background
The Access Arrangement for the PTS by VENCorp was approved by the Commission under section 2.19 of the Victorian Third Party Access Code for Natural Gas Pipeline Systems (the Victorian Access Code) on 16 December 1998.
Clause 5.1.2 of the Access Arrangement provides that:
‘in the event that the MSOR becomes subject to an exemption under section 51(1) of the Trade Practices Act, any amendment to, or supplementation or replacement of, the MSOR will, to the extent to which the MSOR are part of this Access Arrangement, constitute a change for the purposes of the Code and will not be effective to change this Access Arrangement unless and until the procedure in section 2 of the 
On 21 November 1998, the Gas Industry Act 1994 (Vic) was amended by the insertion of section 62PA which statutorily authorises the making of the MSOR (including any amendment to the MSOR) and things done or conduct engaged in by VENCorp, participants or market participants pursuant thereto.  Section 62PA came into force on 2 December 1998.  The MSOR are subject to an exemption under section 51(1) of the Trade Practices Act 1974 (Cth).  The proposed changes to the MSOR concern Rules that are part of the Access Arrangement. For these reasons, the proposed Rule Changes constitute proposed revisions to the Access Arrangement.
3.	Procedure for assessing proposed revisions
VENCorp lodged its application for amendment pursuant to section 2.33 of the Victorian Access Code.  Section 2.33 of the Victorian Access Code allows the Commission to approve proposed revisions to the Access Arrangement without requiring production of Access Arrangement information or public consultation if:
(a)	the revisions have been proposed by the Service Provider other than as required by the Access Arrangement; and
(b)	the Relevant Regulator considers that the revisions proposed are not material.
VENCorp stated that the proposed Rule Changes:
•	replace the original MSOR requirement for VENCorp to develop and incorporate principles and procedures for approving or rejecting proposed connections, with obligations to develop and publish guidelines to the same effect; and
•	modify the metering requirements of the MSOR to ensure consistency with a decision by the Office that it should not be mandatory for customers who consume less than 100TJ per annum to have telemetry fitted to their metering installations.
VENCorp argued that these proposed revisions (as constituted by the proposed Rule Changes) do not impact on the Access Arrangement in any material respect.
In the course of its public consultation relating to an application by VENCorp for minor variation of the authorisation of the MSOR, the Commission sought the views of interested parties on whether the proposed Rule Changes are material to the Access Arrangement (insofar as they constitute proposed revisions).  One submission was received from Energex but this did not address the materiality issue.    
The Commission accepted the view that the proposed revisions are not material to the VENCorp Access Arrangement and decided to dispense with the requirement to produce Access Arrangement Information and the consultation process outlined in section 2 of the National Access Code. 
4.	Criteria for assessing proposed revisions
Section 2.46 of the National Access Code provides that the Commission may approve proposed revisions to an Access Arrangement only if it is satisfied the Access Arrangement as revised would contain the elements and satisfy the principles in sections 3.1 to 3.20 of the Code.  In assessing proposed revisions, the Commission must take into account:
•	the factors described in section 2.24 of the Code; and
•	the provisions of the Access Arrangement.
4.1	Requirements of section 2.24
Section 2.24 requires that the Access Arrangement contains the elements and satisfies the principles set out in sections 3.1 to 3.22.  These sections set out the elements that an Access Arrangement must include as a minimum – namely a services policy, Reference Tariffs, terms and conditions, a capacity management policy, a trading policy, a queuing policy, an extensions/expansions policy and a review date.
Section 2.24 also requires that the Commission take into account:
(a)	the legitimate business interests of the Service Provider;
(b)	firm and binding contractual obligations of the Service Provider or other persons (or both) already using the Covered Pipeline;
(c)	the operational and technical requirements necessary for the safe and reliable operation of the Covered Pipeline;
(d)	the economically efficient operation of the Covered Pipeline;
(e)	the public interest, including the public interest in having competition in markets (whether or not in Australia);
(f)	the interests of Users and Prospective Users; and
(g)	any other matters that the Relevant Regulator thinks are relevant.
As noted earlier the proposed revisions deal with the following areas:
•	implementation of obligations on VENCorp to develop and publish guidelines for approving or rejecting proposed connections; and
•	implementation of metering and telemetry requirements that are consistent with the Office’s decision with regard to implementation of retail contestability.  
The Commission considers that these proposed revisions do not remove any of the elements of the VENCorp Access Arrangement that was approved under section 2.19 of the Code on 16 December 1998.  Moreover, the Commission considers that the proposed revisions do not affect the substance of the Access Arrangement in such a way that takes it outside the principles set out in sections 3.1 to 3.22.
The Commission has taken the matters set out in section 2.24 into account and considers that the proposed revisions do not impact on the Access Arrangement in such a way that the Commission should no longer consider that the Access Arrangement contains the elements and satisfies the principles set out in sections 3.1 to 3.20 of the National Access Code. 
4.2	The provisions of the Access Arrangement
The minimal effect of the proposed revisions on the substance of the Access Arrangement means that the provisions of the Access Arrangement do not require any redrafting.
5.	Decision
The Commission has taken into account the factors described in section 2.24 of the National Access Code and the provisions of the Access Arrangement, and is satisfied that the revised Access Arrangement contains the elements and satisfies the principles set out in sections 3.1 to 3.20 of the National Access Code.
Pursuant to section 2.46 of the National Access Code, the Commission approves the proposed revisions which are the subject of this application.

ANNEXURE A: PROPOSED RULE CHANGES

GUIDELINES FOR APPROVAL OF CONNECTION APPLICATIONS

4.1	CONNECTION 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 in the guidelines referred to in clause 4.1.7(f)  and give notice of the approval or rejection to the relevant Transmission Pipeline Owner.

(c)	VENCorp may reject a proposed connection if the proposed connection or modified connection does not meet the system operation and security and other requirements specified in the guidelines referred to in clause 4.1.7(f).
(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.

In consultation with Participants VENCorp must develop and update from time to time guidelines for the approval of new or modified connections to the transmission system.

(g)	The guidelines referred to in clause 4.1.7(f) must:

(1)	contain the principles and procedures and the system operation and security requirements used for approving or rejecting a proposed connection referred to in clause 4.1.7(b); and 
(2)	must be published and provided to Participants and interested persons on request 
 		
METERING AND TELEMETRY REQUIREMENTS

3.7	PRUDENTIAL REQUIREMENTS

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

a level determined and published by VENCorp in consultation with Market Participants. 

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 based on substituted or available profiled metering data in accordance with procedures developed and published from time to time by VENCorp in consultation with Market Participants.

(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.

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: 

(1)	for connection points on the transmission system;

(2)	for distribution delivery points at which gas is withdrawn by:

(A)	Market Customers; and

(B)	Customers who are purchasing that gas in its entirety from a person other than the Local Retailer; and

(3)	for distribution delivery points as determined by VENCorp :

(A)	for the purposes of giving effect to an allocation algorithm developed in accordance with clause 3.5.4; or 

(B)	for which metering data is otherwise required for the purpose of settlement.

(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; 

(AA)	receipt point on a distribution pipeline;

(B)	distribution delivery point at which gas is withdrawn by a Market Customer or a Customer who is purchasing gas in its entirety from a person other than the Local Retailer; and

(C)	distribution delivery point as determined by VENCorp for the purposes of giving effect to an allocation algorithm developed in accordance with clause 3.5.4,

(D)	distribution delivery point for which metering data is otherwise required by VENCorp for the purpose of settlement

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 a metering installation:

(A)	used to measure the consumption of a transmission delivery point complies with the relevant standards prescribed in this clause 4.4; and

(B)	used to measure the consumption of a distribution delivery point complies with the relevant standards prescribed in the Distribution System Code.

(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 or collection and delivery to the metering database in accordance with this clause 4.4; 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: 

(A)	a metering installation at a transmission delivery point in accordance with clause 4.4.9; and

(B)	a metering installation at a distribution delivery point in accordance with the accuracy limits set out in the Distribution System Code;

(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)	Market Participants are entitled to access to the metering database in respect of injections or withdrawal of gas for which they are financially responsible;

(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 or otherwise collected from metering installations and delivered 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.

4.4.6	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 or otherwise collected from the metering installation and delivered to the metering database, and be capable of communication with the metering database, as required and in accordance with clause 

(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 with a date and time stamp being applied for each trading interval;

(fa)	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 :

(1)	35 days, if the metering installation enables VENCorp to obtain remote access in accordance with clause 4.4.18; or

(2)	70 days, if the metering installation does not enable remote access by VENCorp in accordance with clause 4.4.18. 

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 or otherwise collected and delivered to the metering database from its metering installations:

(1)	within the applicable accuracy parameters described in schedule 4.1 for metering installations at transmission delivery points, and in the Distribution System Code for metering installations at distribution delivery points;

(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);  

(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; and

(4)	in accordance with the requirements of clause 4.4.18,
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.

4.4.18	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 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 or otherwise collected from the metering installation and delivered 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), for all delivery points at which Customers withdraw 100,000GJ of gas per annum or more, and all distribution delivery points identified prior to 1 September 2000 at which Customers withdraw more than 10,000GJ per annum and for which metering data is required for the purposes of the allocation algorithm developed in accordance with clause 3.5.4, 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.

4.4.22	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 required under clause 4.4.18(d) and 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).

4.4.24	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 or otherwise collected from a metering installation and delivered 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;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 Partcipant;

(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 Partcipant;

(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.

Addition to Chapter 11; Glossary :

data logger	A device that collects and stores energy data or volume data and is capable of either :

(a)	transfer of recorded data to a portable reading device; or

(b)	being accessed electronically by VENCorp via the data collection system, 

as required for metering installations in accordance with clause 4.4.18.