What is actually being decided

Package 1 of the review is running alongside two rule change requests, and the submissions respond to all of it at once. Endeavour Energy’s covering letter names the set: the review itself, the rule change request by Energy Networks Australia (ENA) in relation to Enabling distribution network service provider led electric vehicle charging infrastructure, and the rule change request by Nexa Advisory (Nexa) in relation to Clarifying distribution ringfencing in emerging markets.

Strip the acronyms and it is one question with two halves. Ring-fencing is the rule that keeps a monopoly network out of markets where competitors could operate, because a business whose revenue is guaranteed by regulation should not be able to lean on that while competing. The ENA wants the rules loosened so networks can build EV charging. Nexa wants them tightened, or at least clarified in the direction of more restriction. The networks are the parties being fenced.

Three declines, three registers

None of the three NSW distributors supports the Nexa proposal, and the way each says so is worth reading, because it tells you how each of them argues.

Ausgrid is blunt. Ausgrid does not support Nexa's proposed reforms. Its objection is one of sequence: We consider the classification of emerging services should precede decisions regarding ring-fencing, rather than Nexa’s framing in reverse. On the substance it says the proposals to lift detailed obligations into the National Electricity Rules and to introduce a last-resort test for waivers would introduce subjectivity and reduce flexibility.

Endeavour Energy is brief. We do not support Nexa’s rule change request, and separately that Competition is an important factor in how it reads the question.

Essential Energy does not say no. It says not yet, and frames the proposal as evidence for its own argument: The Nexa proposal illustrates why an integrated decision-making framework is required. It allows that the proposal raises legitimate questions about the future regulatory treatment of emerging services, then asks the Commission to establish the broader decision-making framework governing service classification, ring-fencing and shared assets before considering individual rule change proposals affecting those instruments.

Same destination, three routes: Ausgrid on the merits, Endeavour in a line, Essential on process. A reader who only saw one of these submissions would come away with a different impression of how contested this is.

The kerb is a city argument

The second finding is the one you can only get by putting the three side by side, and it is about what each network chose to spend its words on.

Counting mentions in the text of each submission:

  • Ausgrid: kerbside 48, ring-fencing 130, Nexa 47
  • Endeavour Energy: kerbside 2, ring-fencing 11, Nexa 7
  • Essential Energy: kerbside 0, ring-fencing 10, Nexa 3

Ausgrid’s submission runs to 45 pages against eight and nine for the others, so some of that gap is simply length. The zero is not a length effect. Essential Energy describes itself in its opening as the regional distribution network service provider (DNSP) for NSW managing more than 194,000 km of powerlines, covering 95% of the State serving 900,000 customers across regional, rural and remote communities. A network whose customers mostly have a driveway has little reason to argue about the kerb.

That is not a criticism of Essential Energy, and we are not making one. It is a description of how a national rule gets argued: the party with the most at stake writes the most, and the question that dominates the file is the question that matters in the cities.

What Ausgrid actually wants to do

Ausgrid supports the other rule change, and says why in a sentence that is unusually concrete for a regulatory submission. It backs the ENA proposal as the most efficient way to unlock kerbside electric vehicle (EV) charging, and argues that the ENA’s open access proposal means DNSP-led kerbside chargers will increase, not reduce, competition in public charging.

Then the part that lands closest to home: Under this rule, Ausgrid would accelerate EV uptake by solving the ‘overnight home charge’ problem for residents without off-street parking.

That is the whole argument in one line. If you rent a terrace or live in a flat, you cannot run a cable to a car, and the public fast charger is a different product at a different price from charging slowly overnight. Ausgrid is saying it can fix that if the rules let it, and that letting it will make the charging market bigger rather than smaller. Nexa’s position is the opposite, that a monopoly moving into a contestable market needs restraining first.

Our view, labelled as such: the competition claim is the one to watch and the one nobody can settle from a submission. A network offering open access to its kerbside assets could plausibly widen the market, and a network that owns the kerb could plausibly foreclose it, and which happens depends on terms that do not exist yet. What we can say is that the Hunter’s distributor has told the regulator it wants to build them, and that the case it is making is about people who have nowhere to plug in at night.

What we have not done

We read three submissions of more than fifty. The AER, AEMO, Energy Networks Australia, Energy Consumers Australia, the Justice and Equity Centre, major users and Tesla are all in the file and unread here, and Nexa Advisory’s own rule change request is characterised only through what these three say about it, which is an interested account by definition. Anyone wanting the other side should read Nexa directly. We have also not put questions to any of the three networks; this is a reading of what they filed.

How we did this

The three submissions were downloaded from the AEMC’s Package 1 page and read in full on 26 August 2026: Ausgrid 45 pages, Endeavour Energy 8, Essential Energy 9. Every quotation is from the submission attributed to it.

The mention counts are ours, from a case-insensitive count of each term in the text extracted from each PDF. They measure what a submission spends words on and nothing else. A count includes headings, footnotes and the contents page, and the three documents are very different lengths, so the counts are comparable in direction and not in magnitude. The one that carries weight is the zero, because no amount of length explains it.

One access note. The AEMC page at aemc.gov.au/market-reviews-advice/electricity-network-regulation-review resolves to Package 1 rather than the current package, which is useful rather than broken: it is where the Package 1 submission PDFs are listed, under /sites/default/files/ paths by month. All three fetched cleanly with a plain request.

The documents

  1. Ausgrid, submission to the Electricity Network Regulation Review Package 1 (PDF, 45 pages, read 26 August 2026): the statement that it does not support Nexa’s proposed reforms, the classification-before-ring-fencing sequence argument, the subjectivity and flexibility objection, the support for the ENA rule change as the most efficient way to unlock kerbside EV charging, the open-access competition claim and the overnight home charge passage.
  2. Endeavour Energy, submission to the same review (PDF, 8 pages, read 26 August 2026): the description of the review and the two rule change requests, and its statement that it does not support Nexa’s rule change request.
  3. Essential Energy, submission to the same review (PDF, 9 pages, read 26 August 2026): its description of itself as the regional distributor with more than 194,000 km of powerlines covering 95 per cent of the state and 900,000 customers, the integrated decision-making framework argument, and the request that the framework be established before individual rule changes are considered.
  4. AEMC, Electricity Network Regulation Review Package 1: the page carrying the submission list, read 26 August 2026.

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