perlboy
commented
1 year ago While I'm in support of the objective of the thematic of this proposal it is likely legally insufficient to state "energy retailers do not have to expose" because Rules override the Standards and NP248 specifically includes a statement of:
In light of the obligations and context outlined above, this section describes a series of suggested implementation patterns that can be used by energy retailers to meet their obligations under the CDR rules and standards.
The proposed Rules wording suggests that the Standards set one or more processes for forwarding which the noting paper and the official DSB account suggested it had. Further the rules also talk about a transfer mechanism for the request that should also be unambiguously clarified.
What is absent from the Rules (and possibly DSB) consideration is why the Register can't be a mechanism for lookup of base uris suitable for retrieving this data. It is, in essence, exactly that for Banking now.
Pasting the Rules for reference:
A retailer that has not chosen to provide a product data request service must nevertheless, if: (a) it becomes aware that a CDR consumer is attempting, or has attempted, to make a product data request for required product data to it or through it; and (b) the standards set one or more processes for forwarding such a request to the AER or the Victorian agency as appropriate; forward the request using one of those processes in a way that conforms with the relevant data standards.
On this basis it is critical the Standards are more explicit than "do not have to" and in fact state explicitly that they do not specify such a process so that observers are not confused, mislead by or rely upon previous statements made by the DSB. It's also important to explicitly outline that the Standards neither provide a mechanism to forward nor to transfer such a request so Energy retailers voluntarily providing Energy PRD (if they exist or are about to exist) will become immediately non-compliant.
Suggested wording would be something like:
- "With respect to CDR Rules Schedule 4, Part 4(2) the Standards do not currently specify a mechanism to transfer the request to the AER or the Victorian Agency" and;
- "With respect to CDR Rules Schedule 4, Part 4(3) the Standards do not currently specify one or more processes for forwarding Energy Plan and Energy Plan Detail requests to the AER and the Victorian agencies. "
nils-work
Description
The Treasury have recently published the exposure draft rules for non-bank lending. This includes some proposed rule changes to address the issues uncovered last year around the discovery of energy PRD endpoints served by AER. These rules are intended to resolve the obligations for energy retailers with regard to PRD endpoints and are proposed to indicate that this obligation will be realised via the standards.
To avoid the need for an implementation date to be included in the rules the DSB are suggesting that the standards be amended to indicate that there is no obligation on retailers. This would effectively be a formalisation of the current state situation but it would also mean that the rules can be made without creating an immediate obligation.
The DSB would then consult with the community on removing this statement from the standards along with a reasonable future dated obligation.
Area Affected
There are two options for the area of the standards to be changed:
Change Proposed
A statement would be added to the standards to the effect that energy retailers do not have to expose energy PRD via their public base URI