Decision Proposal 197 - Candidate Account End Points

[CDR-API-Stream]

This decision proposal contains a recommendation for the candidate URIs and end points for energy accounts.

The decision proposal is embedded below:
Decision Proposal 197 - Candidate Account End Points.pdf

Note that this proposal has incorporated changes arising from the generic tariff consultation (for the tailored structure). It also incorporates initial feedback from AEC members on incorporate C&I customers.

This consultation will be open for feedback until the 22nd October 2021.

[EnergyAustraliaBA]

Attaching a pack (pdf) that was provided by EA to the Data Standards Advisory Committee (DSAC) re C&I customers and CDR. Has relevance for DPs 197 and 198. This pack identifies specific data issues relating to Billing, Tailored tariff and Meter data.
Aligned to the information in this pack, one key callout is that our Mass Market and C&I subject matter experts (SMEs) have identified that it’s not compatible to have both payloads on the same API endpoint.
DSAC - EnergyAustralia presentation 8 Sep 2021.pdf
.

[EnergyAustraliaBA]

Please find below - and in the two attached documents - EnergyAustralia’s response to Decision Proposal 197 (Account End Points, which include tailored tariff data).
Note that this feedback reflects our initial assessment from a business perspective, and is provided prior to commencing detailed assessments and overall ‘solutioning’.
The two attached pdfs are: 1. Overall and field by field feedback for both the Mass Market and C&I customer segments, and; 2. a Data Set summary providing our initial assessment of each dataset from a C&I perspective.

Some of the key items included in our detailed feedback are:

Overall

• After careful analysis and consideration with our Mass Market and C&I SMEs, EA believes it is not compatible to have both Mass Market and C&I data payloads on a single API endpoint - see attached documents for further detailed information. Therefore EA recommends that DSB separates the Mass Market and C&I Data payloads into two separate API Endpoints.

Mass Market segment

• See overall comments on Page 2 of the attached MM and C&I feedback document
• Concessions data: not all concessions fit the attributes described

C&I segment

• We believe many data sets are “not serviceable” (meaningful data cannot be provided) or are “partly serviceable” (data can be provided but may not meet CDR expectation and context). Some key examples of this are:
  o “Plans” as such don’t exist for C&I like they do for mass market (where there is a plan that is widely marketed under a particular name). In contrast C&I products are highly bespoke/negotiated with the customer. As such we are unable to meaningfully populate this data.
  o “Detailed Account Data” section - Charges generally and additional “pass-through” data
  o Pricing and Discounts don’t cover C&I customers as additional types of pricing are used in C&I and pricing is not discounted in the same way as mass market plans (i.e. prices are just set lower)

EA Decision.Proposal.197.-.Candidate.Account.End.Points_MM and CI feedback.pdf
EA Decision Proposal 197_Dataset Summary_C&I perspective.pdf

[AGL-Sumit]

Please find attached AGL's consolidated response for decision proposal #197 and #198:

AGL Decision Proposal response for 197 and 198.pdf

[PratibhaOrigin]

As raised with the Commonwealth Treasury and DSB, we remain concerned with the proposed inclusion of large Commercial and Industrial (C&I) energy consumers within the CDR framework. C&I businesses enter into energy pricing arrangements that are markedly different from “traditional” retail pricing structures commonly used for (small) mass market consumers. C&I consumers largely rely on unbundled rates, the direct pass through of costs (ie determined at the time of billing), have separate contracts for different services (ie metering, network connection) or could have rates that span over a number of sites. A challenge for CDR is how to adequately capture these differences at an efficient cost and whether brokers (who largely request data on a C&I’s behalf) is able to directly utilizes the services of CDR.

For this Account End Point API (current tariff details), we understand that the intent of this API is to provide the consumer with a view of their rates that they can expect to see on their statement as opposed to a copy of their energy contract. For C&I consumers, this may only be a proportion of the total charges relevant to the consumer as some rates are dependent on other market participants (ie network, AEMO, metering provider).
At a high level, the following changes have been proposed for C&I consumers if a decision is made to include them and the scope is only limited to the Invoicing, Billing & Account payloads. If there is a decision made by Rules team on the inclusion of C&I consumers, we would like to review all other APIs, including the common APIs from a C&I perspective.

Account Detail Payload
• The transaction type or charge type categories across all 3 APIs will need to be expanded to cater to the various unbundled categories represented on an Invoice. The proposed list of categories is “usage”, “generation”, “onceOffCharge”, “onceOffDiscount”, “environmentalCharge”, “regulatedCharge”, “networkCharge”, “meteringCharge”, “retailServiceCharge”, “RCTICharge”, and “otherCharge”
• Contract level accounts with no linked consumers will be left out of scope as these accounts only hold contract details and are not used for billing
• "demandCharges", "controlledLoad" and "dailySupplyCharges" blocks within the Account Detail API are not going to be applicable for C&I customers as these will be passed through from the network and we will display these (if applicable) under the "networkCharges" category
• The format for all applicable rates (time of use, metering, environmental, regulated etc.) should include the rate, unit of measure, start date and end date
• The enumeration list against "fee term" should also include a VARIABLE option to cater to fees where the term is not fixed. For example, if a customer terminates their contract before the agreed end date, they may be charged a variable fee that is calculated using different elements or factors
• Rename "tariff" to "usageCharge" as the block only refers to usage or energy charges
• "pricingModel" and "timezone" to be moved to the "usageCharge" category as these fields relate to energy charges only
• In case we are not able to provide all the data for a given account for any reason – could be that the pricing is highly bespoke or a new product has been introduced with charges and features not supported by the current payload structure – how are these expected to be handled? Would a new field be available for us to populate why we cannot provide the data?
• It is understood that C&I consumers would be required to individually request data on an account-by-account basis. That is, if a customer has 10 accounts with a retailer, they need to provide consent for each and every account.
• Pg-4 refers - Concession & Hardship Data . However, our understanding based on the draft rules is that ‘hardship’ details are now kept out of scope of CDR . Reference – Rule 1.3 of Schedule 4 of the Rules. Can DSB confirm the same ?

Concession Data
• For C&I customers, concessions would be applicable if there are any eligible persons residing at the property for a given bill period. So, this is dependent on the number of people at the property and not related to the end customer (for e.g., caravan parks). Therefore, we will not be able to provide the data in the requested format which is tailored to mass market and propose that C&I customers be left out of scope for this API

Further feedback (at a field level) has been provided in the attached document. For a detailed list of fields proposed to be modified, added, and removed, please refer the attachment.
DP 197 Account API ORIGIN - October 2021.docx

[CDR-API-Stream]

This consultation is now closed. Feedback will be reviewed and responded to as soon as possible to allow for a final cut of candidate energy standards by 1st of November

[CDR-API-Stream]

In response to feedback from @EnergyAustraliaBA:

• After careful analysis and consideration with our Mass Market and C&I SMEs, EA believes it is not compatible to have both Mass Market and C&I data payloads on a single API endpoint - see attached documents for further detailed information. Therefore EA recommends that DSB separates the Mass Market and C&I Data payloads into two separate API Endpoints.

The reasoning for having two separate endpoints is unclear. The ADRs will not know if the customer is C&I or not and consequently will not know which endpoint to call.
Having a single endpoint provides ADRs a clear way of requesting account information without prior knowledge of type of customer (which they would not have). There are other ways of structuring the payload to service both C&I and retail customers which we can consider if there is feedback from other contributors as well.

[CDR-API-Stream]

There is substantial field level feedback provided. This is very helpful and will be incorporated as far as possible along the lines of following principles:

• The CDR has an existing set of approaches for optional sub-objects (ie. union types) and these will be used if necessary where different object types are suggested
• Optionality will be incorporated where suggested but these may be made "conditional" and depending on other aspects (such as customer type) rather than simply being made optional
• As these changes are occurring fairly close to the candidate date we don't have much time to iterate on these changes. As a result we will create some specific change requests in standards maintenance to act as a vehicle for ongoing discussion

[CDR-API-Stream]

Please find attached the final decision of the Chair:
Decision 197 - Candidate Account End Points.pdf