Submission: AER - Network performance reporting for regulated electricity and gas networks

6 November 2025

To: Australian Energy Regulator
Re: Network performance reporting for regulated electricity and gas networks
 

Thank you for the opportunity for the Institute for Energy Economics and Financial Analysis (IEEFA) to provide input to the AER’s consultation paper on Network performance reporting for regulated electricity and gas networks.

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 has found the AER’s network performance reporting data to be valuable, and it is an important element of ensuring transparency and accountability for network performance and the effectiveness of the regulatory regime.

However, we see significant room for improvement in the data that is included in these reports. Some critical insights – such as absolute profits by network, and absolute profits above the benchmark level – are not reported on in the AER reports, and this has a significant impact on the ability to assess the effectiveness of the regulatory regime.

Gas networks face a unique context of declining demand, and the AER should consider what data would be most helpful to help governments and other market actors to facilitate this phase-down in a managed way that best supports consumers.

Export services will become increasingly important, and it will be useful to track this under updated utilisation metrics.

Our detailed responses can be found in the following pages. Please don’t hesitate to contact us in case of any enquiries.
 

Kind regards,

Jay Gordon, Energy Finance Analyst, Australian Electricity, IEEFA
Johanna Bowyer, Lead Electricity Analyst, Australian Electricity, IEEFA