Submission: AEMC – Gas networks in transition – draft determination

8 October 2026
 

To: Australian Energy Market Commission
Re: Gas networks in transition – draft determination
 

Thank you for the opportunity for the Institute for Energy Economics and Financial Analysis (IEEFA) to provide input to the draft determination for Gas networks in transition.

IEEFA is an independent energy finance think tank that examines issues related to energy markets, trends and policies. The Institute’s mission is to accelerate the transition to a diverse, sustainable and profitable energy economy.

IEEFA thanks the Commission for its consideration of the issues surrounding gas networks, which are important as the electrification transition accelerates. While we support some aspects of the draft determination, in some areas we consider it has diverged significantly from the original intent of the rule change request.

We are most concerned by the Commission’s draft determination on accelerated depreciation, including limitations on regulators’ ability to exercise discretion in approving networks’ proposals. We consider the “switching point” analysis underlying the draft determination flawed, as networks are most likely beyond this switching point.

To illustrate these concerns, the first section of our submission contains a short piece of analysis of the impact accelerated depreciation on gas network charges in Victoria – where significant levels of residential electrification are already occurring, and likely to accelerate.

The second section summarises IEEFA’s core concerns with the draft determination, several of which were raised in our previous submission.

The third section summarises our view on how the draft determination, in the form proposed by the Commission, could be improved to achieve better outcomes for consumers.

Please do not hesitate to contact me with any questions about our submission.
 

Kind regards,

Jay Gordon – Energy Finance Analyst, Australian Electricity