This submission is in response to the AEMC’s wholesale gas market discussion paper, to outline design options for the proposed changes to the Victorian declared wholesale gas market. The new design will require new governance roles, capacity allocation mechanism, pricing and revenue allocation from capacity trading and market balancing procedures. PIAC is generally supportive of the proposed design options for the Southern Hub. However, PIAC has requested that the AEMC provide additional information and conduct further consultation with consumer advocates to enable them to more meaningfully participate in this complex and technical process.