We appreciate the opportunity to respond to the Australian Energy Regulator’s (AER) consultation on its Draft Decision for the Jemena Gas Networks (JGN) access arrangement proposal for 2020-25 (the revised proposal).

We engaged TRAC Partners to undertake a technical review of JGN’s initial and revised access arrangement proposals, which can be read here. This assessment has raised key issues where further thought and discussion are required: the treatment of uncertainty and accelerated depreciation; consumer engagement; and pricing.

With the help of TRAC Partners, we have concluded that the unique position of the AER means they are best placed to help further the sector’s discussion about the ongoing reform of the economic regulatory framework. We have raised several issues in this submission that we believe the AER can elevate above the framework.

Read the full submission here.