30th October 2025

Australian Sustainable Built Environment Council (ASBEC), the Justice and Equity Centre (JEC),  and Nature Conservation Council of New South Wales (NCC) welcome the opportunity to respond to the Australian Energy Market Commission’s (AEMC) Gas Networks in Transition consultation paper. This process is a critical and overdue opportunity to ensure the regulatory framework for gas networks is fit for purpose and capable of best promoting the interests of consumers throughout the energy system transition.

The current legal and regulatory framework for gas networks is fundamentally unfit for purpose. It is founded on an assumption of continuity and indefinite growth in the gas network, and in many cases assumes active promotion of this growth as promotes efficiency. This is no longer appropriate in the context of the energy transition. It distorts decision making and effective assessments and promotion of efficiency and the consumer interest.

The rule change proposals in this process highlight specific issues within the regulatory framework which can be regarded as ‘symptoms’ of this wider unfitness for purpose. We welcome the AEMCs efforts to identify other aspects of the framework which are similarly unfit and should be considered for appropriate reform.

Read the full submission including the 10 key recommendations here.