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Jemena
22 Aug 2022

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Jemena

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22 August 2022

Jemena Limited
ABN 95 052 167 405

By online submission Level 16, 567 Collins Street
Melbourne, VIC 3000
PO Box 16182
Melbourne, VIC 3000
Department of Industry, Science and Resources T +61 3 9173 7000
GPO Box 2013 F +61 3 9173 7516
www.jemena.com.au
Canberra ACT 2601

To whom it may concern

Options to improve the Australian Domestic Gas Security Mechanism

Jemena welcomes the opportunity to comment in response to the Options to improve the Australian
Domestic Gas Security Mechanism issues paper (the Paper).

Jemena owns and operates gas transportation and processing infrastructure across eastern and northern Australia, and has invested significantly in the development of Australia’s gas markets over the past decade. Our portfolio of assets includes a number of major gas transmission pipelines, as well as the Jemena Gas Network which distributes gas to over 1.4 million homes and businesses in
New South Wales.

We recognise the role of the Australian Domestic Gas Security Mechanism (ADGSM) in responding to the concerns of energy users in the east coast market relating to supply security and affordability, and we broadly support the seven guiding principles outlined in the Paper. This is particularly the case given the critical roles lower-emission natural gas plays in our energy system—both delivering more end use energy than electricity1 as well as the increasingly vital firming role of gas powered generation to support variable renewable electricity growth as base load coal retires.

Consistent with the principles of ensuring sufficient supply of gas to the domestic market and minimising implementation cost and complexity for government and industry, the Australian
Government should consider ways of ensuring that market participants have flexibility—including transport neutrality—in how they respond to an Exporter Market Security Obligation in the context of a rapidly evolving east coast gas market. Transport neutrality could, for example, allow a project to increase east coast supply from domestic or global sources via an LNG import terminal, supporting
Australia’s position as a trusted export partner.

More broadly, Jemena encourages the Commonwealth to continue to collaborate with state and territory governments to enable new sources of gas supply. As noted in the Paper, continued investment in gas supply is critical to the future of Australia’s energy market, and as such, both the
ADGSM and broader energy market reforms being considered by Energy Ministers must be guided by the need to support and encourage new investment.

We also strongly believe the Commonwealth and state and territory governments should continue to play a role in encouraging the development and uptake of renewable gases—including hydrogen and biomethane. Such action would be consistent with the Paper’s stated objectives relating to energy security, affordability and supporting the energy transition in line with climate action goals,

1 Energy Networks Australia, Gas Vision 2050: Delivering a Clean Energy Future, September 2020.
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while also potentially reducing the need for mechanisms such as the ADGSM to be relied on over the longer-term.

Should you have any questions, please contact James Harding, Gas Markets Regulation Manager, at james.harding@jemena.com.au.

Yours sincerely

Ana Dijanosic
General Manager Regulation

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