March 13, 2025
In line with the Victorian Government's dedication to implementing the recommendations from the Embedded Networks Review, a Gas Embedded Networks General Exemption Order (GEN GEO) has been issued for the supply of gas within existing gas embedded networks under the Gas Industry (GI) Act (GEN GEO 2025).
Embedded network operators will fall under a general exemption order to supply gas in networks that were operational on or before 25 February 2025 without a license, until 30June 2031. This exemption applies only to the supply of gas in embedded networks and does not extend to the sale of gas by entities without a license.The GEN GEO 2025 outlines specific conditions that must be fulfilled to operate the supply of gas within an embedded network, ensuring that customers in these networks receive adequate protections.
- From 25 February 2025, operators must provide customers with contact details and information about their arrangements, as well as fall under the new abolishment requirements.
- From 26 May2025, operators will need to join the Energy and Water Ombudsman (Victoria)(EWOV) and adhere to the Gas Distribution Code of Practice.
Gas embedded networks established after 25 February 2025 must possess a license or an exemption to distribute or supply gas; otherwise, each customer needs to be directly connected to the local gas distributor's network.
In October 2018, the Victorian Government committed to banning electricity embedded networks in new residential apartment buildings, with certain exceptions. The government’s response to the Embedded Networks Review, published in July 2022, supported all recommendations from there view. The Victorian Government has made claim that the GEN GEO 2025 partially addresses Recommendation 13 by reinstating protections for gas embedded network customers Unlike the detailed consulting process for electricity under the previous review, the gas provisions released are distanced from those recommendations by both time and purpose. Stakeholders should take note of the Victorian Government’s intent and use of the review to rush through change. This may include a similar release of the licensing framework for Embedded networks that was proposed under the review.
The GEN GEO 2025 mirrors existing distribution obligations for electricity embedded network operators under the electricity General Exemption Order 2022. This includes:
These obligations are largely consistent with those applicable to gas distribution licensees.
The GEN GEO 2025establishes new regulations regarding the abolishment of gas meters in embedded networks. If an embedded network operator plans to deactivate the gas network and abolish the parent meter, there are limitations on what they can charge their customers. Customers may only be charged a pro-rata amount, which cannot exceed the fees set by the local gas distribution company for the parent meter abolishment.
If a customer decides to fully electrify their property and disconnect from the gas embedded network (whether a metered or unmetered child connection point), the network operator is required to:
Given the unique characteristics of gas embedded networks, the process for abolishment may differ from that of detached premises. Customers can initiate a request for abolishment through their retailer or directly with the embedded network operator.
The GEN GEO 2025 does not require gas embedded network operators to register their networks in a Register of Exempt Persons. However, those exempt under the GEN GEO 2025 must supply information to the ESC by or before 30 June each year.
The GEN GEO 2025 is a civil penalty requirement.This means that the ESC can enforce compliance with conditions in the GEN GEO2025, such as providing information to the ESC and complying with applied provisions of the Gas Distribution Code of Practice, through initiating civil penalty proceedings in court.
Navigating the intricate landscape of embedded network regulations demands expertise. ENM Solutions is one of only few independent providers in the market. This independency enables us to perform the ENM Function and expert consultancy as an unbiased and trusted third party for Owners, Tenants and Operators, with no perceived or actual conflict of interest.
Retaining the independence of this role also allows us to be agnostic to the partners of all stakeholders involved, rather than bringing pre-determined suppliers or partnerships with us, that you may be locked into. Working with you, our independence can unlock valuable attention and resources that allow you to focus on the big picture.
Contact us today to discuss how we can work together to take you forward.
