Energy Consumers Australia welcomes the opportunity to provide feedback to the Australian Energy Regulator (AER)’s draft decision on Jemena Gas Networks’ access arrangement 2025 to 2030.

We are pleased to see the AER has not accepted Jemena’s proposed capex and substituted it with a lower estimate, particularly regarding meter replacement and by rejecting costs related to connecting eight biomethane production facilities.

These decisions demonstrate that Jemena must begin planning for a network in decline.

However, there remains significant risk to consumers inherent in the AER’s decision, much of which cannot be avoided through the AER’s actions alone. This highlights that there is a growing need for broad action to ensure consumers pay a fair and affordable price for gas for as long as they need it.

In this submission, we argue that the AER:

• should not allow Jemena to accelerate the depreciation of any of its assets in this proposal;
• encourage upfront costs are charged whenever possible and only approve capital for new connections that is absolutely necessary under the existing rules;
• require Jemena to provide more information on opportunities for strategic decommissioning;
• continue to disallow any expenditure for biomethane connections; and,
• not consider Jemena’s engagement a sufficiently broad representation of consumer sentiment.