We appreciate the opportunity to make a submission to the Australian Energy Regulator (AER) on the Evoenergy and Australian Gas Networks (SA) gas access arrangement revised proposals 2021-26

We believe that the revised proposals from Evoenergy and AGN (SA) are closer to being considered capable of acceptance, and use this submission to add comment on the future of gas distribution networks. In framing our response to the various pathways proposed for the future of the gas networks operated by Evoenergy and AGN SA, we have focussed on the impact this transition will have on consumers. It appears that in every instance, consumers will face replacing their current appliances that use gas at some stage as part of the transition. Not only does this have direct cost impacts for consumers, but how the remaining investment costs are recovered also raises equity issues – both vertical and intergenerational.

Specifically, there is a risk to the most vulnerable energy consumers – those who don’t have the capacity to pay or to switch to alternative forms of energy – footing the bill for increased costs as businesses seek to recover the costs of their investments over a shorter period of time through accelerated depreciation.

We would welcome the approach of consideration of these key elements outside a regulatory reset process through more appropriate mechanisms such as AER reviews or Australian Energy Market Commission (AEMC) reviews and rule changes.

Read our full submission here.

Our supporting Technical Reports can also be read here:

• Technical Report: – Evoenergy Revised Access Arrangement Proposal
  2021-26
• Technical Report: – AGN SA Revised Access Arrangement Proposal –
  2021-26

These submissions are the final in the series, click here to read our previous submission.