Energy Consumers Australia welcomes the opportunity to provide this submission to the Gas Market Reform Group (GMRG) regarding the Capacity Trading Reform Package (Reform Package). The COAG Energy Council has already approved certain design elements of the gas capacity trading mechanism, which are reflected in the Reform Package.
Accordingly, the submission primarily focuses on aspects of the Reform Package in respect of which the GMRG has specifically sought feedback. Energy Consumers Australia’s submission is supplemented by a legal analysis by Maddocks Lawyers of relevant legislative and regulatory provisions contained in the Reform Package.
These are critical reforms that should be implemented in a timely and transparent manner faithful to the COAG Energy Councils intention to secure a step-change in the levels of transparency and competition in gas wholesale markets in the long-term interests of consumers. The GMRG, the Australian Energy Regulator (AER), the Australian Energy Market Commission (AEMC) and the Australian Competition and Consumer Commission (ACCC) should continue to closely monitor and report on the effect of the reforms to ensure that the reforms lead to a decrease in the price of gas delivered to consumers and end-users and that, if so, both this outcome and the effect of the reforms in achieving it are clearly communicated to consumers and large end-users.
A review of the impact and effectiveness of the Reform Package and broader gas market reforms in achieving the National Gas Objective and, particularly, serving the long-term interests of consumers following implementation, should be hard-wired into the regulatory framework. This review should be based on accurate information that can form a sound and reasonable basis for conclusions and recommendations regarding any amendments that might be needed to the new gas market arrangements.
The full submission can be read here.