The Procedure Change Process has been reviewed as required by clause 2.16.13F of the WEM Rules. Under this clause the Coordinator must ensure that an independent person carries out an audit of the effectiveness of the Procedure Change Process no less than every three years.
The Procedure Change Process Review is being undertaken in three stages:
Stage 1: Independent Procedure Change Process audit
Stage 2: Procedure Change Process design changes
Stage 3: WEM Amending Rules and procedure changes
Stage 1: Independent audit of the effectiveness of the Procedure Change Process
To fulfil the requirements for an independent audit under the WEM Rules, ACIL Allen was engaged by the Coordinator to undertake Stage 1 of the review, and recommend any necessary changes.
ACIL Allen’s Consultation Paper was published on 6 May 2024 and set out the initial recommendation and observations on the effectiveness of the Procedure Change Process. Four public submissions were received in response to this paper.
On 28 June 2024, ACIL Allen submitted a final report to the Coordinator, delivering its independent assessment of the Procedure Change Process, including six recommendations for potential improvements:
- Recommendation 1
A standard covering sheet should be developed, which would sit on top of Procedure Change Proposal reports. It would require a standardised summary of the proposal.
- Recommendation 2
A minor amendment pathway should be developed for Procedure Changes that do not have an impact on Rule Participants, which would streamline the process and reduce administrative burden for these minor matters.
- Recommendation 3
The WEM Rules should be amended to expand the class of entity which can initiate a Procedure Change Proposal from “Rule Participant” to “person”.
- Recommendation 4
A timeframe should be introduced for when a Procedure Change Proposal is initiated by a third party.
- Recommendation 5
The publishing requirements imposed on AEMO under clause 2.9.2D of the WEM Rules should be extended to all Procedure Administrators.
- Recommendation 6
A drafting philosophy would be developed and adopted to guide the drafting of the WEM Rules and provide guidance as to the appropriate instrument for matters.
On 09 August 2024, the Independent Audit Final Report and the Coordinator’s response to the recommendations were published in the Coordinator’s website, in accordance with clause 2.16.13F(b) of the WEM Rules.
Stage 2: Procedure Change Process design changes
Following the Independent Audit, the Coordinator is developing a consultation paper with a set of proposals to amend the Procedure Change Process in the WEM Rules, to be released shortly. This consultation paper will contain an Exposure Draft of any proposed WEM Amending Rules.
