Gas reform has been a focus of government over a number of years. The implementation of the current reform process is now concluding, with most initiatives expected to be in place by mid-2020.
Every two years the Australian Energy Market Commission (AEMC) is obliged to report to the COAG Energy Council on the state of liquidity in the wholesale gas and pipeline trading markets. The last review, conducted in August 2018, showed that liquidity is improving, and will continue to do so as further reforms are implemented. The Australian Competition and Consumer Commission (ACCC) has also completed a series of reports, making recommendations along the way, with its most recent interim report delivered in July this year. However significant environmental barriers to onshore gas exploration on the east coast remain.
Here we take a deep-dive into the background, current regulatory frameworks and the potential future trends of Australian gas developments.
Natural gas is Australia’s third largest energy resource after coal and uranium. Reserves are classified according to their technical and commercial prospects of recovery, as shown in Figure 1 below.
Source: Geoscience Australia
Proved & Probable (i.e. 2P) Reserves across Australia total approximately 108 exajoules (108,000PJ), of which 39EJ is connected to east-coast markets. The east coast also has a further 30EJ of sub-commercial Proved & Probable Contingent (i.e. 2C) gas resources.
To give an idea of the magnitude of these resources, Australia produces (for domestic consumption and export) approximately 5EJ p.a., therefore Australia has over 20 years of supply available – without any further exploration and development.
Focusing on the National Electricity Market (NEM), last financial year east coast production was 1.9EJ, therefore again there are more than 20 years’ reserves available. The location of the reserves is set out on the following map.
Due to their age, southern gas reserves, predominantly the Gippsland Basin, are declining, as shown in the following graph (figure 3). Nevertheless, within the limits of the Victorian Government’s gas exploration policy, other explorers have commenced offshore development, and these are expected to supplement Victorian production in future years.
To bring the gas to load centres, there are a number of major transmission pipelines, as shown in the following map.
Since gas transmission pipelines have monopoly elements, the sector is subject to varying degrees of regulation, being:
Australia’s national demand is set out in the following diagram.
Source: Department of the Environment and Energy
Over the past ten years, Australia’s east coast gas demand has increased markedly, due to the commissioning of the Liquefied Natural Gas (LNG) plants in Queensland.
Underlying east-coast gas demand has remained flat, with the only material variation being the consumption of gas in NEM gas-fired generation which is heavily affected by both gas price and electricity conditions. After recent declines, GPG is predicted to increase over coming years.
Given the level of transparency in the market, reporting of gas prices is limited, and commentators generally report the Short-Term Trading Market prices as a proxy, noting that they may not be reflective of longer-term arrangements.
Gas Market Reform
Gas reform has been a focus of government over a number of years. In December 2012 the Standing Council on Energy and Resources agreed to an Australian Gas Market Development Plan, and this was followed in December 2014 by the COAG Energy Council releasing its Australian Gas Market Vision, which built on existing reforms and set out 12 specific outcomes, broken into 4 work streams, as follows:
The Australian Gas Market Development Plan was updated in December 2015, and superseded in August 2016 by the COAG Energy Council’s Gas Market Reform Package, which responded to the ACCC’s 2016 East Coast Gas Inquiry and the AEMC’s East Coast Wholesale Gas Market and Pipeline Frameworks Review by establishing a dedicated Gas Market Reform Group to focus on 4 priority areas (gas supply, market operation, gas transportation and market transparency) and implement 15 reform measures, including establishing 2 primary trading hubs and a gas transportation capacity market.
The August 2017 Energy Council Gas Supply Strategy is a successor to the December 2015 Australian Gas Market Development Plan and was amended by the Council to recognise onshore conventional gas more explicitly, and to include offshore gas and underground gas storage, as part of a more holistic approach to national gas supply, and to meet community expectations in regard to the use of resources. It suggested four focus areas for the states and territories to collaborate, including improving information on gas reserves and production potential, improving public information and improving the regulatory frameworks for gas development.
The implementation of the reform process is now concluding with most initiatives expected to be in place by mid-2020.
Every two years the AEMC is obliged to report to the COAG Energy Council on the state of liquidity in the wholesale gas and pipeline trading markets. The last review, conducted in August 2018, concluded that liquidity is improving, and will continue to do so as further reforms are implemented. The next review will be conducted mid-2020.
ACCC gas inquiries
On 13h April 2015 the Minister for Small Business,Bruce Billson, commissioned the ACCC to hold a public inquiry into the competitiveness of wholesale gas prices and the structure of the upstream, processing, transportation, storage and marketing segments of the east coast gas industry.
The 2016 East Coast Gas Inquiry made a number of findings, including:
This report spurred the gas market reform detailed above, and in April 2017 the Government directed the ACCC to conduct a wide-ranging inquiry into the supply of and demand for wholesale gas in Australia, as well as to publish regular information on the supply and pricing of gas for the next three years. On 6 August 2019 the Government extended the ACCC Gas Inquiry to December 2025.
The most recent interim report, July 2019, reported that:
The Interim Report also indicated that the ACCC will, over the course of the Inquiry, conduct a closer review of:
WA has maintained a domestic gas reservation policy since 1979 when it helped underwrite the development of the North-West Shelf LNG project. It currently requires new developments to set aside 15 per cent of their LNG productions for domestic sale, and to offer such gas in good faith to domestic consumers. Given the large size and low costs of the conventional WA LNG export projects, this creates conditions for domestic WA gas to be valued below international prices.
Queensland has its own domestic gas reservation policy in the form of the Petroleum and Gas (Production and Safety) Act (Qld) 2004. It reserves particular petroleum leases solely for supply into the Australian market. The small size of the reservation and the relative development costs mean that the influence upon domestic prices could not replicate the WA situation.
In consideration of such policies, the ACCC’s East Coast Gas Inquiry found that, “[t]he gas supply issues … would not be fixed by a reservation policy; in fact they could be worsened if a reservation policy was enacted which artificially depressed prices in the short term and discouraged investment in new gas supply, thus reducing the likelihood of required supply diversity.”
Its recommendation was that “gas reservation policies should not be introduced, given their likely detrimental effect on already uncertain supply”.
Australian Domestic Gas Security Mechanism
On 1 July 2017 the Commonwealth Government established the Australian Domestic Gas Security Mechanism (ADGSM) to be in place until December 2022, in response to fears of possible shortfalls, highlighted by AEMO’s 2017 GSoO. The ADGSM allows the Minister for Resources to restrict LNG exports if the Minister has reasonable grounds to believe that there will not be a sufficient supply of natural gas for Australian consumers during the year unless exports are controlled, and that exports of LNG would contribute to that lack of supply. It does not have a price trigger.
At this time the ADGSM has not been invoked, however additional domestic supply has been made available from the exporting companies since the 2017 outlook under the Gas Supply Guarantee (discussed below), arguably influenced by this threat.
On 6 August 2019 the Government announced:
Gas Supply Guarantee
In March 2017, Production Facility Operators and Pipeline Operators made commitments to the Commonwealth Government to make gas available to meet peak demand periods in the National Electricity Market. The Gas Supply Guarantee is a mechanism developed by the gas industry to facilitate the delivery of these commitments.
The mechanism took effect on 1 December 2017 and expires 31 March 2020.
Production Facility Operators propose to meet this commitment by making additional gas supply available to Gas Generators through Facilitated Markets or contractual arrangements during peak NEM demand periods, while Pipeline Operators propose to meet this commitment through:
Gas market transparency
Increased gas market transparency has been advocated by the COAG Energy Council and the ACCC since 2012. Most recently, in its July 2019 Interim Report the ACCC stated that increased transparency is to be encouraged to facilitate market liquidity, and proposed a series of measures in its Measures to improve the Transparency of Wholesale Prices in the Gas Market – ACCC Recommendations Report. These included expanding its monthly LNG netback price series and reporting on the wholesale gas prices payable by domestic gas users to producers and retailers for contracts longer than 12 months’ duration.
Environmental barriers to exploration
There are significant environmental barriers to onshore gas exploration in the east-coast.
NSW has does not have commercial conventional natural gas resources available, and has relied on coal seam gas for indigenous supply, however new developments, notably Santos’ Narrabri development, have been stymied by “the toughest coal seam gas regulations in Australia”. These regulations include development oversight by a Land and Water Commissioner, banning the use of BTEX chemicals and evaporation ponds, codes of practice on coal seam gas exploration, and referrals to the NSW Minister for Primary Industries and the Commonwealth Independent Expert Scientific Committee for advice on water impacts. The Environment Protection Authority is the lead regulator.
In contrast, NT conducted a “Scientific Inquiry into Hydraulic Fracturing”, and concluded that onshore gas exploration, drilling and fracking can occur in designated zones, subject to environmental conditions. It is now developing regulations for production.
Victoria, however, has an onshore conventional gas moratorium in place until 30 June 2020, and an ongoing unconventional gas ban.
In the future the gas supply-demand balance may be affected by three possible, major influences.
Declining gas consumption
As discussed above, despite recent increases in gas use as a result of LNG exports and population growth, underlying gas consumption has reduced in domestic and commercial & industrial sectors. Domestic consumption has been reducing due to the displacement of gas for heating and hot water by electricity, as a result of the ready availability of solar panels for self-generation and local requirements for energy efficiency measures in new homes, although this has been partially offset by increases due to population growth. Industrial usage has been most affected by declines in Australian manufacturing, according to the media and EUAA as a result of cripplingly high gas prices, but there are other influences such as labour costs, local demand for products, the exchange rate and international competitiveness which have affected these companies’ decisions.
In time there may be pushes to reduce gas consumption in order to reduce carbon emissions. The ACT Government has declared, in its quest for zero emissions by 2045, that it will discourage the use of natural gas in both residential and commercial uses by removing the mandated requirement for gas connection in new suburbs, supporting gas to electric appliance upgrades and transitioning to all-electric new builds.
Fluctuations in the use of gas for generation
Gas-fired generation accounted for 7.6 per cent of the NEM’s generation last financial year, but has varied over the past ten years, as shown in Figure 7 above. As the NEM’s generation mix changes, this proportion may change, with an accompanying variation in gas consumed.
In December 2018 the COAG Energy Council established a Hydrogen Working Group, chaired by the Chief Scientist, Dr Alan Finkel AO, to develop a National Hydrogen Strategy to:
As currently formed, the strategy proposes developing renewable hydrogen, which will foster the production of hydrogen for:
While gas reform has been a key focus, significant barriers to gas exploration on the east coast remain. Removing unnecessary regulatory burdens and lifting restrictions on exploration may provide the right set of conditions for industry to explore and develop new gas resources. The role of gas will remain dependent on its competitive position as a fuel, competing on price and sustainability, and lifting restrictions will assist in this regard.
 Australian Energy Market Commission, Gas Market Liquidity Review Final Report, 26th June 2018
 EnergyQuest, EnergyQuarterly – September 2019 Report, 5th September 2019, p.71
 Reserves represent that part of resources which are commercially recoverable and have been justified for development, while contingent resources are less certain because some significant commercial or technical hurdle must be overcome prior to there being confidence in the eventual production of the volumes.
 EnergyQuest (op.cit.), p.110
 Ibid., p.74, Figure 25
 See 4.6 Environmental Barriers to Exploration
 Australian Energy Market Operator, Victorian Gas Planning Report, March 2019, p.35, Figure 17
 Australian Energy Regulator, State of the Energy Market 2018, December 2018, p.223, Figure 5.1
 Department of the Environment and Energy, Australian Energy Update 2019, September 2019, p.10, Figure 2.3
 Australian Energy Market Operator, Gas Statement of Opportunities for Eastern and South-Eastern Australia, 28th March 2019, p.17, Figure 4
 Ibid., p.27, Figure 12
 COAG Energy Council, Australian Gas Market Vision, 11th December 2014
 COAG Energy Council, Gas Market Development Plan, December 2015
 Australian Competition & Consumer Commission, Inquiry into the East Coast Gas Market, April 2016
 Australian Energy Market Commission, East Coast Wholesale Gas Markets and Pipeline Frameworks Review – Stage 2 Final Report, 23rd May 2016
 COAG Energy Council, COAG Energy Council Gas Supply Strategy, 4th December 2015 (revised August 2017)
 Australian Energy Market Commission, Gas Market Liquidity Review Final Report, 26th June 2018
 Australian Competition & Consumer Commission (2016),
 The Hon Josh Frydenberg MP & Senator the Hon Matthew Canavan, Joint Media Release, 6th August 2019, available at https://minister.environment.gov.au/taylor/news/2019/government-acts-deliver-affordable-reliable-gas
 S&P Global – Platts, Study on Global Natural Gas Prices to End-Users for Australian Competition & Consumer Commission, June 2019
 Australian Competition & Consumer Commission, Gas Inquiry 2017-2020 Interim Report, July 2019
 Australian Competition and Consumer Commission (2016), p.68
 Australian Competition and Consumer Commission (2016), p.20, Recommendation 2
 Australian Energy Market Operator, Gas Statement of Opportunities for Eastern and South-Eastern Australia, 9th March 2017
 Customs (Prohibited Exports) (Operation of the Australian Domestic Gas Security Mechanism) Guidelines 2017
 Australian Competition & Consumer Commission, Measures to improve the Transparency of Wholesale Prices in the Gas Market – ACCC Recommendations, 2019
 Australian Capital Territory Government, ACT Climate Change Strategy 2019-25, 2019, p.6
 i.e. hydrogen produced by the electrolysis of water, the power source for which is renewable energy
The focus around AEMO’s latest assessment of gas supplies for eastern Australia was on its improved outlook. One change in its expectations for gas demand flows from the potential of gas-fired generation in the National Electricity Market. AEMO expects gas-fired generation demand to become more “peaky” and to switch to peaking in winter instead of summer.
A perennial discussion in energy market policy is the contest between what we are ultimately trying to achieve: “customer benefits” or “market benefits”. When making market rules, or building monopoly assets, rules require that we assess “net market” benefits. A number of recent government policies have been justified on customer benefit assessments alone.
The economics of traditional plants are well understood, but since their construction, the way they need to operate has changed substantially. This has been driven by a combination of the age of the plants as well as the large influx of renewables, which is changing the supply and demand patterns of the grid.
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