Great Southern Energy Gas Networks Pty Ltd, ACN 083 199 839 (GSN) owns a gas distribution system in Wagga Wagga. This distribution system is a 'covered' pipeline pursuant to section 1.1 of the National Third Party Access Code for Natural Gas Pipeline Systems (the Code). GSN as a Service Provider is required to meet the minimum ring fencing obligations outlined in the Code unless the Tribunal grants a waiver pursuant to section 4.15 of the Code. In an application to the Tribunal on the 16 December 1998, GSN sought a waiver from section 4.1(h) and (i) of the Code (provisions dealing with the separation of marketing staff).