EUAA Submission: AER Enhanced Wholesale Monitoring & Reporting Guideline – Issues Paper

EUAA Submission: AER Enhanced Wholesale Monitoring & Reporting Guideline – Issues Paper

Emily Wood | May 8, 2024

‘…Thank you for the opportunity to make a submission under the Australian Energy Regulator’s (AER) Enhanced Wholesale Market Monitoring and Reporting Guideline. While the Issues Paper covers both electricity and gas, our particular focus is on the east coast gas market given it has substantially less transparency to consumers than the National Electricity Market.

The EUAA supports the efficient operation of wholesale markets that have efficient structure and performance and have good conduct practices at their core. Successive ACCC Gas Market Reports[1] since the first in 2016 have highlighted the lack of competitive markets across the gas supply chain that has enable supply side players to exercise market power. Drawing on our members experience, the EUAA had long argued this was the case but our advocacy was rejected by the supply side. It was only when the ACCC was able to gain access to and publish information about the operation of the gas market did we get independent evidence that our position was indeed the case. This lack of competition and exercise of market power remains today even with the many reforms that have occurred in upstream and transport parts of the supply chain.

The EUAA has welcomed the various reforms that have flowed from these ACCC reports, most recently the creation and implementation of the Mandatory Gas Code of Conduct (Code of Conduct) and now reforms on gas pipeline regulation and tariff disclosure. Nevertheless, the exercise of market power continues in the gas market. A necessary, but not sufficient condition to mitigate that market power is transparent and timely market reporting on what is occurring. So we welcome the new wholesale market monitoring and reporting powers now available to the AER for the both electricity and gas market…..’



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