EUAA Submission: AEMO ECGS Reliability & Supply Adequacy Functions Consultation Paper
Emily Wood | February 13, 2026
What this will do is establish modelling and triggers to advise the market to avoid gas shortfalls and if the market does not make up the shortfall, then AEMO’s powers will be triggered and AEMO will intervene. With similar measures already in the NEM, we see AEMO stepping in and directing generators and/or loads to ensure the system is balanced. The downside is that usually the cost of AEMO intervention is paid for using a consumption-based approach, rather than a user-based approach, and hence large loads get hit with the biggest bills.
‘…We continue to be conscious of the negative impact of regulatory change on investor confidence and the willingness for counterparties to enter into long-term Gas Supply Agreements (GSA’s) and we hope that with a satisfactory outcome from the current reform processes, including the successful introduction of a domestic gas reservation scheme, that governments will no longer feel compelled to intervene in gas markets to protect Australian energy users.
After a period of uncertainty there is now widespread support for the continuing role for gas in terms of both electricity generation to support a VRE dominant energy system and as an input to our manufacturing industries that supply products consumers use every day. However, while attitudes have shifted, the need for decisive action has never been more acute. It is the experience of EUAA members that the market has failed to supply gas at competitive terms and conditions, despite well-meaning government intervention over many years. The reasons for this have been well articulated in the Gas Market Reform Final Report.
The uncompetitive state of the domestic gas market is particularly problematic for manufactures exposed to international competition and extreme pressure from low cost imports. These factors, along with significant international uncertainty driven by financial and military conflict, has stymied the ability of large commercial and industrial customers to enter into long-term gas supply agreements. Unfortunately we have already seen demand destruction occurring with a number of significant industrials closing their doors in recent years with escalating gas prices seen as a major contributor to these decisions2….’
Please download attached document to read full submission.
