EUAA Submission: APA Gas Transmission Access Arrangements

EUAA Submission: APA Gas Transmission Access Arrangements

Emily Wood | September 8, 2022

‘…This short submission comments on the AER’s Draft Decision and APA’s Revised Proposal. The EUAA is a member of the APA Stakeholder Engagement Group.

The major issues for our members are highlighted in the Draft Decision and summarised by APA’s ‘balancing competiting objectives’ narrative:

  • demand is going to fall, but by how much and how fast following the policy announcements in the Gas Substitution Roadmap plus the very large rises in spot and contract gas commodity prices?
  • how do you reconcile a large increase in capex with an argument for accelerated depreciation?
  • how do you balance the need to meet peak demand that may only occur for a few days in the next few years when the only option (in the absence of a demand management mechanism) to meet that peak is assets that have a life of >40 years and APA then wants to accelerate their depreciation? …’

Please download attachment to read full submission.

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