INVESTIGATION | 4 November 2026
A consultancy firm advised both government and the gas industry on the same gas policy - without declaring a conflict of interest.
A Climate Integrity investigation reveals that consultancy firm ACIL Allen advised both the government and the gas industry on gas policy – including the influential Future Gas Strategy – without declaring a conflict of interest.
Drawing on documents obtained under Freedom of Information (FOI), “Working both sides of the fence” shows that throughout 2023 and 2024, ACIL Allen was commissioned by the gas industry and the federal government to deliver analysis to inform gas policy.
At times, ACIL Allen was working for industry and government at the same time.
The report also analyses six of the reports produced by ACIL Allen for government and the gas industry - finding that the consultancy often adopted assumptions and methodologies that overstate the case for more gas and understate the benefits of a faster transition to renewables.
This raises questions about the adequacy of conflict-of-interest safeguards governing government-commissioned advice and about the integrity of parts of the evidence base behind one of Australia's most consequential energy policies.
By Alexandra Blucher and Michael Mazengarb
Working both sides of the fence
In 2023 and 2024, consultancy ACIL Allen was paid by gas industry groups to produce reports that were then used to lobby on the Future Gas Strategy. Over the same period, it was paid by the federal government to deliver analysis to inform that same strategy.
ACIL Allen did not declare a conflict of interest to the government.
One of the policies that ACIL Allen worked on for both government and industry was the Future Gas Strategy (FGS). This is one of the most significant policy statements in Australia’s energy transition. It sets out the role of fossil gas in the economy through to 2050, and has faced criticism for backing new gas supply that’s inconsistent with a net zero pathway, and for underplaying the role of renewables and storage.
Key Findings
ACIL Allen held a conflict of interest during its $273,713 contract for the Department of Climate Change, Energy, the Environment and Water (DCCEEW) – work intended to inform the development of the Future Gas Strategy and broader gas policy – because it had recently completed work for gas and business lobby groups Gas Energy Australia and the Business Council of Australia, which was used in the organisations’ submissions to the Future Gas Strategy.
ACIL Allen failed to disclose a conflict of interest to DCCEEW, even though the Supplier Code of Conduct was in force when the reports related to the Future Gas Strategy were delivered.
In 2023, ACIL Allen was working for industry and government on gas policy at the same time.
Reports produced by ACIL Allen for both gas industry interests and the federal government adopt a consistent stance that gas should remain a feature of Australia’s energy system to 2050 and beyond, recommending that government support is provided to enable the development of new gas supplies.
ACIL Allen’s analysis consistently overstated the cost of zero emissions alternatives to gas, while also entirely omitting any assessments of the costs of developing new gas supplies through worsening climate harms.
DCCEEW told Climate Integrity that ACIL Allen did not declare any conflicts of interest related to the contracts identified in this report. ACIL Allen did not respond to questions asking whether it declared any conflicts to the government and how conflicts were managed, if at all.
What our FOIs uncovered
Documents obtained by Climate Integrity through Freedom of Information (FOI), along with open source research, shows that over a nearly two year period ACIL Allen worked on:
Three reports for industry associations representing fossil fuel interests. Including Gas Energy Australia, the Business Council of Australia, the Australian Pipelines and Gas Association and Energy Networks Australia. These reports were used in submissions to the Future Gas Strategy and Electricity and Energy Sector Plan consultation processes. The report for Gas Energy Australia was quoted in the Future Gas Strategy report, with no reference to who commissioned the work.
Two reports for the Department of Climate Change, Energy, the Environment and Water (DCCEEW) One advised on east coast gas market reforms and another (delivered in two parts) was commissioned to inform the Future Gas Strategy and the Energy and Electricity Sector Plan.
Figure 1: Timeline of ACIL Allen’s engagement on gas policy analysis, for both government and industry clients, corresponding with the development of the Future Gas Strategy
ACIL Allen’s reports for Government:
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A contract between ACIL Allen and DCCEEW, which ran between August and November 2023, was worth $77,121 and was an impact analysis of potential reforms to the east coast gas market. At the same time as it was working on this contract for the government, ACIL Allen was also working on:
a report for industry group, Gas Energy Australia, about the economic contribution of the gas industry – a report which was subsequently used in industry submissions to the policy and directly quoted in the Future Gas Strategy.
a report for the Australian Pipelines and Gas Association and Energy Networks Australia, called the Renewable Gas Target, which was later used in the organisations’ submissions to DCCEEW’s Electricity and Energy Sector Plan.
a report for the Business Council of Australia (BCA), which went on to form part of the BCA’s submission to the Future Gas Strategy.
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Another contract, signed in February 2024, asked ACIL Allen to provide modelling and analysis to determine what gas powered generation (GPG) or renewable alternatives may be needed in the medium and long term and an assessment of gas supply and infrastructure future needs.
FOI documents show the Statement of Work from DCCEEW to ACIL Allen stated the work would “inform the development of the Government’s Future Gas Strategy for consideration by Government in Q1 and Q2 2024 and the Energy and Electricity Sector Plan”
The $273,713 contract resulted in a report, Gas-powered generation and gas infrastructure modelling delivered in July 2024, with another supplementary report delivered five months later.
original FREEDOM OF INFORMATION DOCUMENTS available at:
Conflict of interest
By working on gas policy both for the government and for gas industry clients, ACIL Allen has a conflict of interest. Its clients’ in the gas industry have a direct financial interest in the outcomes of government policy, on which it is also advising.
DCCEEW told Climate Integrity that ACIL Allen did not declare a conflict of interest related to the contracts identified in this report.
Following the PwC tax leak scandal, the Commonwealth introduced a Supplier Code of Conduct, which took effect on 1 July 2024. Its very first expectation is that suppliers declare and manage conflicts of interest. Under the Code, failing to declare a conflict is considered a “severe” breach.
ACIL Allen delivered its main report to DCCEEW four days after the Code came into effect, and a supplementary report five months later. DCCEEW did not answer our question about whether it updated ACIL Allen’s contract to include the Code. ACIL Allen did not respond to our questions.
However, previous guidance that was in place when the two DCCEEW reports were commissioned said public servants involved in contract management should ensure any conflict of interest declarations were provided by suppliers when setting up the administration of a contract.
DCCEEW and DISR did not respond to Climate Integrity’s questions on how the reports have been used internally.
ACIL Allen did not respond to Climate Integrity’s detailed list of questions asking whether it declared a conflict, whether the same staff worked on reports for both government and industry, and how conflicts were managed, if at all.
Same story, whoever the client
Our review of ACIL Allen’s reports for both industry and government found assumptions and methods that consistently made gas look better than the alternatives.
(Document 6)
(Document 1)
1. ACIL Allen’s analysis consistently over estimated the cost of zero-emissions alternatives to gas
ACIL Allen produced a modelling report for the Business Council of Australia, which formed part of the lobby group’s submission to the Future Gas Strategy consultation.
In this report, ACIL presents gas generation as a lower cost source of firmed electricity supply, compared to zero emissions alternatives - pumped hydro and battery storage. But the analysis primarily focuses on capital costs, largely excludes the higher operating and maintenance costs of gas generation, uses constrained and unrealistic energy market scenarios and ignores the climate costs of gas.
ACIL Allen prepared a very similar analysis in a modelling report for the federal government - reaching the same conclusions with similar methodological issues.
In this report, ACIL Allen compares the cost of the continued use of gas generation to firm Australia’s largest electricity grid to two narrowly constructed alternative scenarios where gas is replaced by zero emissions technologies: one scenario where gas generation firming is replaced only by pumped-hydro projects by 2050, and a second, where all gas firming is replaced by only hydrogen fuelled generators by 2050. In reality, Australia’s future firming needs will be met by a mix of optimised technologies (as reflected in the forecasting approach taken by AEMO).
In ACIL Allen’s full analysis, other zero emissions technologies were excluded as alternatives, including large-scale battery storage, the use of demand management technologies, or expanded investment in solar and wind capacity - or a mixture of renewable energy, storage and demand management technologies - in providing an alternative to gas firming.
In its conclusions, it tells DCCEEW that “[gas powered generation] and supporting gas infrastructure is an economically feasible way to firm the NEM during its transition to net zero.”
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In August 2023, ACIL Allen authored a report for gas-industry lobby group Gas Energy Australia that sought to estimate the economic and employment contributions of the gas industry.
The findings of the report have been repeated extensively by the gas industry, including in a large number of submissions to the Future Gas Strategy. The report was also directly quoted in the Federal Government’s Future Gas Strategy, without mention of the group that commissioned it.
The ACIL Allen report overestimated claims of the contributions the gas industry makes to Australia’s gross domestic product and the number of jobs the sector supports. This was, in large part, due to the assumptions and modelling methodologies chosen to produce the estimates, which included the following issues:
The report’s analysis is based on a single, unrepresentative year when gas prices were significantly and temporarily inflated due to Russia’s invasion of Ukraine.
The gas industry is credited with the ‘indirect’ economic contributions of downstream gas users, including the entire Australian alumina industry and the gas-based Australian chemical manufacturing industry.
ACIL Allen’s analysis does not consider any of the downsides of the gas industry, omitting any consideration of the costs of greenhouse emissions, health impacts, or the subsidies and concessions the sector receives.
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Throughout all of the ACIL Allen reports we analysed, there is a consistent adoption of assumptions and modelling methods that support the case for more fossil gas. Based on the conclusions of its analysis, ACIL Allen advocates for the introduction of policies that support the gas sector.
Further, ACIL Allen told DCCEEW in its July 2024 report that governments should consider taking on some of the risks of gas infrastructure investments:
“Policy risk remains the main barrier to investment in GPG and supporting gas infrastructure, and so minimising this policy risk should be a key priority of governments. If governments found that policy clarity was not sufficient to deliver these investments, they should consider risk-sharing in both gas turbines and gas infrastructure investments.”
ACIL Allen also told DCCEEW that Australia’s “net zero” targets meant gas generators should be allowed to continue operating beyond 2050, even under Australia’s net zero targets:
“Given that the objective of Australian governments is to achieve net zero emissions by 2050, not zero emissions, GPGs should be allowed to operate to 2050 and beyond provided they offset their emissions using credible and verified emissions sinks.”
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Throughout all the reports reviewed by Climate Integrity, ACIL Allen does not adequately consider the implications of future scenarios aligned with 1.5 degrees of global warming, which will require substantial declines in global gas demand.
This approach contributes to ACIL Allen’s conclusions that fossil gas is a cheaper alternative to zero emissions energy storage technologies, and a view that gas will continue to play a prominent role in Australia’s future energy system.
Ultimately, this is a conclusion echoed by the federal government in future gas strategy.
ACIL Allen told DCCEEW:
“Overall, [gas power generation (GPG)] and gas infrastructure has the lowest economic cost of the electricity firming options considered (even accounting for emissions costs), and faces the lowest technical and commercial risk. Based on this assessment, GPG and gas infrastructure will clearly play a key role in firming the NEM on its way to net zero and beyond.
What the Future Gas Strategy says:
“The analytical findings are clear. Under all credible net zero scenarios, natural gas is needed through to 2050 and beyond, though its production and use will change over this period. Gas will be essential to the transition because our energy system needs gas to achieve net zero.”
Our investigation and analysis made a series of Findings and Recommendations for government and consultancies.
Click to expand: Climate Integrity analysis of a graph which was displayed prominently within the Business Council of Australia’s submission to the Future Gas Strategy Consultation. Read more here.
What needs to happen
The Future Gas Strategy is described by DISR as “an evidence-based framework” but this report reveals flaws and conflicts of interests regarding research that was commissioned to inform the policy. Given the conflict of interest was not declared by ACIL Allen, DISR and DCCEEW should retrospectively manage this conflict of interest by disclosing how ACIL Allen’s work was used to inform the Future Gas Strategy, and other gas policy and decision making, and should review and update the policies using sound, independent evidence that is free from conflicts of interest to rebuild public trust in the policies’ credibility.
ACIL Allen, and consultancies more broadly, should assess the climate impacts of their work against stated commitments to climate targets or goals, including ensuring their work is consistent with its own climate commitments. This includes a calculation and disclosure of their ‘serviced or advised emissions’.
Consultancies must prepare and publish a statement of commitment to modelling and information integrity. Consultancies should include a plan for implementing its commitment to information integrity, including full disclosure of commissioning clients, assumptions, modelling methodologies and conflicts of interest.
All government departments and agencies commissioning research and analysis from consultancies must seek guarantees that conflicts of interests will be declared and mitigated. This is particularly important when a consultancy’s clients have a particular interest in the government adopting particular policy positions.
Cite this report:
Climate Integrity (2026). Working Both Sides of the Fence: How ACIL Allen Advised Government and the Gas Industry on the Same Policy, Without Declaring the Conflict. Melbourne: Climate Integrity. Available at: http://climateintegrity.org.au/acil-allen-gas-conflicted
“If part of the evidence base for a major national policy can come from consultants with undeclared industry ties, how can the public trust the policy?
The Future Gas Strategy is set to shape Australia's energy future until at least 2050. It is informing policy making that will shape the energy transition for decades to come. Australians should be able to trust that crucial government decisions about energy are being made based on advice that is free from conflicts of interest.”
Claire Snyder
Executive Director, Climate Integrity
As part of our investigation, we posed the following questions to ACIL Allen, DCCEEW, DISR, the Business Council of Australia, Gas Energy Australia, Australian Pipelines and Gas Association Ltd and Energy Networks Australia.
Only DCCEEW provided a response.
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9 July 2026 – Climate Integrity to ACIL Allen
Climate Integrity has been reviewing the following reports produced by ACIL Allen around the time the federal government was developing the Future Gas Strategy:Economic contribution of the Australian gas economy
Aug 2023: Gas Energy AustraliaThe role of the gas sector in Australia’s transition to net zero
Nov 2023: Business Council of Australia (Future Gas Strategy submission)Renewable Gas Target
Feb 2024: APGA & Energy Networks AustraliaGas-powered generation & gas infrastructure modelling
July 2024: DCCEEW
1. Did ACIL Allen identify a conflict of interest, perceived or actual, relating to conducting work for vested interests—the Business Council of Australia and Gas Energy Australia—on the Future Gas Strategy, and also for the Department of Climate Change, Energy, the Environment and Water in Documents 1 and 2 of these Freedom of Information documents?
2. If not, why not?
3. If yes, how did ACIL Allen record and manage the conflict of interest? Did ACIL Allen declare any conflict of interest to DCCEEW?
4. Did any staff members work on both the Business Council of Australia and DCCEEW advice and modelling related to the Future Gas Strategy? If so, how many and how was the conflict managed?
5. Was the Notice of Significant Event Clause written into the ACIL Allen contract for Document 1 and 2?
6. Was the Supplier Code of Conduct written into the ACIL Allen contract for Documents 1 and 2 after it took effect on the 1st of July 2024?
7. Does ACIL Allen believe it has breached the Supplier Code of Conduct Expectation 1.1 Declare and manage conflicts of interest in connection with Commonwealth contracts?
8. Does ACIL Allen have a house-view on Australia’s obligations and prospects of implementing policies consistent with the goals of the Paris Agreement? Does ACIL Allen have a house-view on the role of gas in a 1.5-degree of warming aligned pathway? If so, what are they?
9. How does ACIL Allen approach settling the key inputs for a piece of analysis commissioned by a client, such as modelling approach, assumptions, scenarios and data sources? To what extent are these set by the client, and does ACIL Allen verify their accuracy or reliability?
10. In several reports, ACIL Allen has modelled single-technology replacements for gas (particularly as a provider of firming electricity generation). Why didn’t ACIL Allen include approaches using least-cost mixed technology portfolios or partial-transition pathways?
11. Do you routinely test your analysis of gas-industry projections against 1.5°C-aligned pathways (e.g. IEA Net Zero)?
12. Where your analysis supports continued or expanded gas, do you flag to clients and government how that sits against a 1.5°C trajectory?
13. Does ACIL Allen have the capability to assess the environmental and climate costs of gas use? Why have these costs been omitted from ACIL Allen’s analysis of the economic impacts of Australia’s gas sector?
14. How does ACIL Allen determine the discount rate(s) used in economic impact assessments? Is the rate set by ACIL Allen, by the client, or through a collaborative process? Where a client specifies or proposes a discount rate, does ACIL Allen independently verify that it is appropriate for the type of analysis being conducted?
17 September 2026 – Climate Integrity to ACIL Allen
Climate Integrity intends to publish an investigation into the advisory and modelling work conducted by ACIL Allen in 2023 and 2024 for both the gas industry and the Department of Climate Change, Energy, the Environment and Water regarding gas policy.
In addition to the earlier list of questions, we’d like to ask a number of further questions related to our investigation.
Freedom of Information documents and the Aus Tender website show that DCCEEW contracted ACIL Allen on 7 July 2023 to do an ‘impact analysis’ of potential reforms to the east coast gas market. The report East coast gas market reliability and supply adequacy Stage 2 reforms: Final impact analysis was delivered on the 30th of November 2023. During the contract period, ACIL Allen was also working on a report for industry group, Gas Energy Australia, on the economic contribution of the gas industry, which was dated as completed on the 6th of August 2023.
Relevant links are here:
https://www.tenders.gov.au/Cn/Show/21ca1715-a528-455f-afa9-0252716dfc9d
https://www.dcceew.gov.au/sites/default/files/documents/81915.pdf (see document 6)
I have the following questions:
1. Did ACIL Allen declare a conflict of interest to DCCEEW under the contract for the report East coast gas market reliability and supply adequacy Stage 2 reforms: Final impact analysis related to its concurrent work for Gas Energy Australia?
2. If yes, how was the conflict manage
3. If not, why not?
4. Did any of the same staff members work on both the East Coast Market Reliability report for DCCEEW and the Gas Energy Australia report?
5. If so, how was the conflict managed?
6. Does ACIL Allen have a general conflict of interest policy, and if so, how are conflict of interests managed?
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25 May 2026 - Climate Integrity to DCCEEW
What, if any, conflicts of interest did ACIL Allen disclose to DCCEEW staff regarding the contracts for Document 1 and Document 2 in this Freedom of Information request? Note that Climate Integrity is the applicant for this FOI request. https://www.dcceew.gov.au/sites/default/files/documents/81915.pdf
If conflicts of interest were disclosed, when and to whom were they disclosed?
If conflicts of interest were disclosed, how and where were they recorded?
If conflicts of interest were disclosed, how were they managed throughout the life of the contract?
Were they made publicly available? If so, where and when?
29 May 2026 - DCCEEW to Climate Integrity
As discussed, the following can be attributed to a DCCEEW spokesperson:
ACIL Allen did not disclose any conflicts of interest under the contract that documents 1 and 2 relate to.
9 July 2026 - Climate Integrity to DCCEEW
1. Can DCCEEW please confirm which contract notice corresponds to Documents 1 and 2? This https://www.dcceew.gov.au/sites/default/files/documents/81915.pdf or this https://www.tenders.gov.au/Cn/Show/46f53f59-4e27-492b-9b27-eab85d24ada2?
2. How have the reports in Documents 1 and 2 been used to inform the Federal Government’s Future Gas Strategy and any related policy and/or programs?
3. When DCCEEW engaged the consultancy ACIL Allen for the reports in Documents 1 and 2, was it aware that ACIL Allen had recently been engaged by the Business Council of Australia to do work that would feed into the lobby group’s submission
to the Future Gas Strategy?
4. If so, did DCCEEW consider this a conflict of interest?
a. If so, what was done to manage and record the conflict of interest?
b. If yes, did DCCEEW check which consultants within ACIL Allen conducted
the work for the Business Council of Australia?
c. If not, why was it not considered a conflict of interest?
5. Did DCCEEW check the submissions to the Future Gas Strategy before commissioning ACIL Allen for the reports in Documents 1 and 2? If not, why not?
6. Did DCCEEW check ACIL Allen’s list of clients and the work completed for them before engaging the consultancy for the work related to the Future Gas Strategy, as outlined in the Statement of Works, Document 3 in the FOI documents? https://www.dcceew.gov.au/sites/default/files/ documents/81915.pdf
7. On 6 August 2023, ACIL Allen delivered a report to Gas Energy Australia on the economic contribution of gas in the 2021-22 financial year. Gas Energy Australia is the national peak body representing gas distributors and other downstream users such as sellers of LPG, like ELGAS. Gas Energy Australia referred to the report in its submission to the Future Gas Strategy three months later: “As reported in ACIL Allen’s Economic Contribution of the Australian Gas Economy 2021-22, LPG drove over $5 billion in domestic economic activity (up from $3.6 billion the previous year), while supporting 20,516 Australian jobs (up from 16,154 a year earlier). ”Australian Energy Producers, Gas Industry Australia and Woodside also quoted the report in their submissions to the Future Gas Strategy. The Future Gas Strategy final report quoted ACIL Allen’s figures for Gas Energy Australia, stating that the gas industry supported 81,940 FTE jobs and $84 billion to the economy in 202122. There was no mention of who commissioned the figures. Was DCCEEW aware that ACIL Allen had conducted the above work for Gas Energy Australia which was used by members of the gas industry in their submissions to the Future Gas Strategy?
8. Was the Notice of Significant Event Clause written into the ACIL Allen contract for
Documents 1 and 2?
a. If yes, does DCCEEW consider ACIL Allen in breach of the Clause considering it didn’t declare a conflict of interest?
b. If not, why not?
9. Was the Supplier Code of Conduct written into the ACIL Allen contract for Document 1 and 2 after it was brought into effect on the 1st of July 2024?
a. If yes, does DCCEEW consider ACIL Allen in breach of the Clause
considering it didn’t declare a conflict of interest?
b. If not, why not?
16 July 2026 - DCCEEW to Climate Integrity
We don’t have any additional comment to what we’ve provided you in May.
21 July 2026 - Climate Integrity to DCCEEW
How has Document 1 in the FOI (pictured below) informed the Electricity and Energy Sector plan (which is part of the Net Zero Plan)? Please include examples of the sections of the reports and the corresponding policies they informed in your answer.
21 July 2026 - Climate Integrity to DISR
1. What gas-related policies, including the Future Gas Strategy and any associated policies or decisions, has DISR used the ACIL Allen reports (Document 1 and 2 in the first FOI link) to inform, as a reference or as an input in any way?
2. Exactly how were the reports used? Please include examples of the sections of the reports and the corresponding policies they informed in your answer.
23 July 2026 - Climate Integrity to DCCEEW and DISR
I have sent questions to both DCCEEW and DISR regarding how ACIL Allen’s reports informed the Future Gas Strategy and other related decision-making on gas and energy policy.
Both departments have referred me to the other; see the email screenshots below.
[NB: SCREENSHOTS REMOVED AS IT INCLUDES INFORMATION PROVIDED ON BACKGROUND WHICH CAN NOT BE REPORTED]
Can you please liaise with each other and provide a response for the following questions:
Climate Integrity has obtained reports through Freedom of Information including Documents 1 and 2 in this Freedom of Information request. https://www.dcceew.gov.au/sites/default/files/documents/81915.pd
Climate Integrity has also obtained the correspondence between DISR and DCCEEW in relation to these reports through FOI. https://www.industry.gov.au/sites/default/files/2026-07/disclosure-log-26-076-300475.pdf
The statement of work for the contract (Document 3 in the first FOI) and the correspondence in the second FOI link shows that DISR was directly involved in dealing with ACIL Allen on the modelling used in the ACIL Allen reports, and was intending to use the reports to inform decisions relating to gas-powered-generation and infrastructure.
We have the following questions regarding these documents. These questions seek a right of reply that will feed into a publication on our website and social media channels examining the role of consultancies, in this instance, ACIL Allen, in informing gas policy development and decision-making.
1. What gas-related policies, including the Future Gas Strategy and any associated policies or decisions, used the ACIL Allen reports (Documents 1 and 2 in the first FOI link) to inform, reference, or serve as an input in any way?
2. Exactly how were the reports used in developing those policies? Please include examples of the sections of the reports and the corresponding policies they informed in your answer.
17 September 2026 - Climate Integrity to DCCEEW
Freedom of Information documents and the AusTender website show that DCCEEW contracted ACIL Allen on 7 July 2023 to conduct an ‘impact analysis’ of potential reforms to the east coast gas market. The report East coast gas market reliability and supply adequacy Stage 2 reforms: Final impact analysis was delivered on the 30th of November 2023.
During the contract period, ACIL Allen was also working on a report for industry group, Gas Energy Australia, on the economic contribution of the gas industry, which was dated as completed on the 6th of August 2023. This report was quoted in the final Future Gas Strategy report.
Relevant links are here:
https://www.tenders.gov.au/Cn/Show/21ca1715-a528-455f-afa9-0252716dfc9d
https://www.dcceew.gov.au/sites/default/files/documents/81915.pdf (see document 6)
https://acilallen.com.au/uploads/projects/767/ACILAllen_GEAEconomicContribution2023.pdf
The Senate Finance and Public Administration References Committee’s inquiry into "the management and assurance of integrity by consulting services provided for the Australian Government" outlined in its report various conflict of interest scenarios, including one matching ACIL Allen's situation: “consulting firms undertake work for the public sector, which relates to work they undertake for private sector clients.”
We are seeking responses to the following two questions regarding the above contract.
Did ACIL Allen declare a conflict of interest regarding the contract listed above that resulted in the report East coast gas market reliability and supply adequacy Stage 2 reforms: Final impact analysis?
If so, did it relate to concurrently working for Gas Energy Australia on the economic contribution report?
If so, how was the conflict managed?
18 September 2026 - DCCEEW to Climate Integrity
The following response can be attributed to a DCCEEW spokesperson:
ACIL Allen did not disclose any conflicts of interest under the contract in question.
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17 September 2026 - Climate Integrity to BCA
We are investigating the work conducted by ACIL Allen related to the Future Gas Strategy and other gas policy for both the Department of Climate Change, Energy, the Environment and Water and industry groups. We intend to publish our findings.
ACIL Allen delivered The role of the gas sector in Australia’s transition to net zero emissions report to the Business Council of Australia on the 13th of November 2023. This was used in the BCA’s submission to the Future Gas Strategy.
Freedom of Information documents show ACIL Allen was contracted in February 2024 by DCCEEW to deliver a report that would inform the development of the Government’s Future Gas Strategy and the Energy and Electricity Sector Plan. See Document 1, 2 and 3 of this FOI: https://www.dcceew.gov.au/sites/default/files/documents/81915.pdf
We’re seeking responses to the following questions, which may be included in our publication.
1. On what date did the Business Council of Australia commission ACIL Allen to deliver The role of the gas sector in Australia’s transition to net zero emissions report?
2. Does the BCA believe there is a perceived or actual conflict of interest in ACIL Allen conducting work providing analysis to DCCEEW on the Future Gas Strategy shortly after its work completed for the BCA related to the same policy? Why/Why not?
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17 September 2026 - Climate Integrity to ENA and APGA
We are investigating the work conducted by ACIL Allen related to the Future Gas Strategy and other gas policy for both the Department of Climate Change, Energy, the Environment and Water and gas industry groups. We intend to publish our findings.
ACIL Allen delivered the Renewable Gas Target: Delivering lower cost decarbonisation for gas customers and the Australian economy report to APGA and ENA on the 16th of February 2024.
https://acilallen.com.au/uploads/projects/868/ACILAllen_RenewableGasTarget_2024.pdf
We are seeking a response to the following question, which may be included in our publication.
What date did APGA and ENA commission ACIL Allen to do the Renewable Gas Target: Delivering lower cost decarbonisation for gas customers and the Australian economy report?
18 September 2026 - Energy Networks Australia to Climate Integrity
This engagement took place in April 2023.
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We are investigating the work ACIL Allen conducted related to the Future Gas Strategy and other gas policy for both the Department of Climate Change, Energy, the Environment and Water and gas industry groups. We intend to publish our findings.
ACIL Allen delivered The economic contribution of the Australian gas economy in 2021-22 report to Gas Energy Australia on August 6, 2023. This report was quoted in the Future Gas Strategy report, and Gas Energy Australia’s submission to the Future Gas Strategy.
Freedom of Information documents and the Aus Tender website show that DCCEEW contracted ACIL Allen on July 7, 2023, to conduct an ‘impact analysis’ of potential reforms to the east coast gas market. The consultancy delivered the report on the 30th of November 2023.
The documents also show DCCEEW contracted ACIL Allen again in February 2024 to deliver a report that would inform the development of the Government’s Future Gas Strategy and the Energy and Electricity Sector Plan.
See Document 1, 2, 3 and 6 of this FOI: https://www.dcceew.gov.au/sites/default/files/documents/81915.pdf
We’re seeking a response to the following questions, which may be included in our publication.
On what date did Gas Energy Australia commission ACIL Allen for the The economic contribution of the Australian gas economy in 2021-22 report?
Does Gas Energy Australia believe there is a perceived or actual conflict of interest in ACIL Allen conducting work for DCCEEW related to the east coast gas reforms at the same time as it was also working on the economic contribution report for Gas Energy Australia? Why/Why not?
Does Gas Energy Australia believe there is a perceived or actual conflict of interest in ACIL Allen conducting work for DCCEEW that would inform the development of the Future Gas Strategy after it had delivered the economic contribution report, which was quoted in the Future Gas Strategy report itself and in Gas Energy Australia’s submission?